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MICHAEL BAILEY

United States Attorney

District of Arizona

RAQUEL ARELLANO

Assistant United States Attorney

AZ State Bar No.: 011796

CHRISTINE A. MELTON 

Assistant United States Attorney

AZ State Bar No.: 021649

United States Courthouse

405 W. Congress, Suite 4800

Tucson, Arizona 85701

raquel.arellano@usdoj.gov

christine.melton@usdoj.gov 

Telephone: (520) 620-7300

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

United States of America,

 Plaintiff, 

 vs. 

Robert Francis Krebs,

 Defendant.

CR 18-00263-TUC-JGZ (JR)

GOVERNMENT’S PROPOSED 

VOIR DIRE

Plaintiff, the United States of America, pursuant to Rule 24(a) of the Federal Rules 

of Criminal Procedure submits the following proposed voir dire questions to the Court and 

respectfully requests the Court to ask these questions of prospective jurors in this case:

1. If you are selected as a juror in this case, you will be instructed that you must 

follow the law as the Court gives it to you. Is there anyone on the panel who 

feels they could not convict someone of a law with which they do not agree, 

even if the government proves its case beyond a reasonable doubt?

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2. Do you, or a member of your family, or close friend work in any field or position 

that involves banks or credit unions? What specifically? Is there anything about 

the work or experiences that would make it difficult to be fair and impartial if 

you were selected as a juror in this case?

3. This case involves the robbery of the Pyramid Federal Credit Union located at

4491 N. Oracle Road, Tucson, Arizona, that occurred on or about January 12, 

2018. Is anyone familiar with this credit union location or the surrounding areas? 

If so, how?

4. Has anyone read, heard or seen anything about this case other than what you 

have been told today? 

5. You will be instructed not to use the computer or internet to research this case, 

or issues that arise in this case, legal or otherwise. Will you promise to do so?

6. Does anyone on the panel believe that federal laws in general punish too harshly? 

Do you understand that if selected to serve as a juror in this case, you will be 

instructed that you are not to consider punishment as that is for the court to 

decide? Will you be able to put any consideration of punishment out of your 

minds and consider only the facts of the case based on the evidence introduced?

7. Does anyone on the panel believe the judicial system in general is unfair? If 

“yes,” please explain why. Would these feelings prevent you from being fair 

and impartial in this case?

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8. Do you have any strong feelings regarding any government policies which 

would prevent you from giving either the government or the defendant a fair 

trial?

9. Is there anyone on the panel who has negative feelings toward, or has had a 

negative experience with, the Federal Bureau of Investigation, Tucson Police 

Department, or other law enforcement officials?

10.Is there anyone on the panel who has negative feelings toward, or has had a 

negative experience with, members of a private security department, such as 

retail security?

11.What, if any, magazines do you subscribe to?

12.Has anyone on the panel or have any members of your family or any of your 

close friends ever been charged with a criminal offense? If so, would that in any 

manner tend to prejudice you, affect your ability to evaluate the evidence or 

otherwise affect your deliberations in this case?

13.Does anyone have a close friend or relative sentenced to federal or state prison?

14.Has anyone on the panel ever been the subject of an investigation by a federal 

agency or have any case pending in federal court at this time?

15.Has anyone on the panel or have any members of your family or any of your 

close friends ever been a victim or a witness in any criminal case? If so, did that 

experience leave a lasting impression? Would that prior experience prevent you 

from being fair and impartial if you were selected as a juror in this matter?

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16.Has anyone on the panel had any training or education in law? What area of 

law? Will you be able to set aside any preconceived notions of the law and follow 

instructions as given to you by the judge?

17.Does anyone on the panel have any members of their families or close friends 

that are lawyers? What area of law? Do they discuss cases with you? If they 

do, do you feel those discussions would affect your ability to be fair and 

impartial if you were selected as a juror in this case?

18.Is there anyone on the panel who would refuse to evaluate and reject a witness’ 

testimony for the sole reason that the witness has been previously convicted of 

a crime, regardless of the content of the testimony?

19.Does anyone on the panel, because of cultural, moral, religious or other beliefs, 

feel that they could not stand in judgment of another individual, or would 

otherwise have difficulty being a juror in a case such as this?

20.Does anyone on the panel suffer from a physical or mental issue that would 

prevent them from being able to serve as a juror in this case? Is anyone on the 

panel currently being treated by a physician or receiving counseling for issues 

that would affect their ability to serve as jurors if selected?

21.Does anyone on the panel know each other? Would that relationship affect your 

ability to be fair and impartial and consider the evidence individually?

22.Would any member of the panel hold the Government to a burden of proving a 

defendant guilty beyond all doubt or to a mathematical certainty rather than 

beyond a doubt that is reasonable? If the government proved its case beyond a 

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reasonable doubt, which the court will define for you, what would your verdict 

be?

23.Does anyone on the panel believe they have the ability, through extrasensory 

perception, clairvoyance, or through any other methods or means, to reach a 

decision about an accused=s innocence, guilt or veracity? If so, please describe 

that condition.

24.Does any member of the panel, for any reason whatsoever, whether I have 

covered the subject or not, believe he or she could not be a fair and impartial 

juror in this case?

Respectfully submitted this 3rd day of February, 2020.

MICHAEL BAILEY 

United States Attorney

District of Arizona

S/ Raquel Arellano 

RAQUEL ARELLANO

s/Christine A. Melton 

CHRISTINE A. MELTON

Assistant U.S. Attorneys 

Copy of the foregoing served electronically 

this 3rd day of February, 2020 to:

Jorge L. Costales, Esq. 

Gregory Berger, Esq. 

Attorneys for the Defendant 

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