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CONFIDENTIAL JUROR QUESTIONNAIRE

Dear Prospective Juror:

You are being considered for the jury in a federal criminal case entitled United States of 

America v. Michael Lacey, et al.

You are ordered not to discuss this case or questionnaire with anyone, including your 

family, friends, and fellow jurors. 

Six individuals (Michael Lacey, James Larkin, Scott Spear, John “Jed” Brunst, Andrew 

Padilla, and Joye Vaught) (“Defendants”) have been charged in a superseding indictment 

with: (1) conspiracy to commit violations of the Travel Act by facilitating prostitution; (2)

violations of the Travel Act; (3) conspiracy to commit money laundering; (4) concealment 

money laundering; (5) international promotional money laundering; (6) transactio nal 

money laundering; and (7) international concealment money laundering. The charges 

arise from the Defendants’ various roles in the creation, operation, and management of the 

website Backpage.com. Defendants have each pleaded not guilty to all charges and are

presumed innocent. The United States has the burden of proving an individual guilty 

beyond a reasonable doubt. 

Do not do any research, including internet searches related to the subject of the case or any 

of the people involved. Do not “google” the names of any of the Defendants or the 

website www.backpage.com. With the limited information you will be provided in this 

questionnaire, if you inadvertently come across any information related to this case, such 

as the Defendants, the website www.backpage.com, the attorneys, or potential witnesses, 

please immediately stop reading as soon as you realize there is a possibility the 

information could relate to this case. Should you encounter (even by mistake) any 

information related to the subject of the case, the website, the people, the attorneys, or 

witnesses involved, you should immediately notify the court. 

Please complete the following questionnaire to assist the attorneys and me in selecting a 

jury to serve in this case. Please answer the questions independently and be honest and

complete with your responses. There are no right or wrong answers. The responses will 

be reviewed only for the purposes of selecting a jury and are designed to help this process 

move along more expeditiously with fewer questions in court. 

Some of the questions may seem very personal. The questions are not meant to invade 

your privacy, but to help select a fair jury. If there is sensitive personal information that 

you prefer not to discuss in front of other jurors, please write “PRIVATE” next to your 

answer to that question, but please still answer the question. If the attorneys need to follow 

up with you about a private response, the attorneys and I will speak to you about that 

response outside the presence of the other jurors. 

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Please write clearly and answer ALL questions. If a question does not apply to you, write 

“N/A” (not applicable) rather than leaving the answer blank. This signals to the attorneys 

and I that the question does not apply to you, instead of leaving us wondering whether you 

missed the question or forgot to answer it. If you do not understand a question, please 

write that in the space provided for the answer.

If you need more space for your response, please use the extra sheet of paper at the end of 

the questionnaire and indicate which numbered question you are answering. Do not write 

on the back of any page. Please use black or blue ink.

Please include your juror number atop each page so we may identify you in the event the 

pages become separated. Please sign the questionnaire when you are finished, your 

answers will be treated the same as if they were made in open court under oath. 

Please return the questionnaire to my chambers by no later than __________.

Thank you for your cooperation.

 

HONORABLE SUSAN M. BRNOVICH

United States District Judge

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JURY SERVICE AND LENGTH OF TRIAL

1. Jury service is one of the highest duties and privileges of a citizen. The participatio n 

of citizens like you is essential to the proper administration of justice. This trial will 

begin August 17, 2020 and is expected to last through November 13, 2020. Trial 

will take place each day from 9:00 a.m. to 4:30 p.m. Tuesday through Friday. 

There will be a break for lunch as well as a short mid-morning and mid-afternoo n 

break. There will be no trial on Mondays. The court recognizes that not everyone 

can serve on a case of this length. However, mere inconvenience or the usual 

financial hardships of jury service will not be enough to excuse you. You must 

show that service in this case would cause an unacceptable amount of personal 

hardship. Keep in mind that if you are unable to serve in this trial, you could be 

summoned for another trial later this year (city, state, or federal). 

Would the length of the trial create an undue hardship?  YES  NO

If YES, which of the following applies to you: (Check all that apply). 

a.  Financial hardship and not paid during jury duty

 Sole provider of income for household

 Self-employed and only paid if working

 Unemployed and actively looking for work

b.  Paid vacation planned during the trial dates

Dates from __________ to __________

Destination: 

Have you purchased tickets?  YES  NO

c.  Scheduled medical surgery or appointments during the trial dates that cannot 

be rescheduled. Dates: 

d.  Am a student attending classes during the trial dates

Dates/Times of classes: 

e.  Have dependent daytime child or elder care responsibility with no substitute 

Relationship: 

Ages of dependent: 

f.  Other Hardship. Please explain in detail: 

 

2. Do you have any difficulties understanding, reading and communicating in the 

English language?  YES  NO

If YES, please explain: 

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3. Do you have any medical, mental or physical conditions (including any caused by 

medications) that would make it difficult for you to sit as a juror or might interfere 

with your ability to concentrate, understand, and consider all of the evidence 

presented at trial?  YES  NO

If YES, please explain:

KNOWLEDGE OF CASE AND CASE PARTICIPANTS

4. Do you know U.S. District Court Judge Susan M. Brnovich or any of her court staff

on any basis, social, professional or otherwise?  YES  NO

If YES, please explain:

5. The Defendants in this case are Michael Lacey, James Larkin, Scott Spear, John 

“Jed” Brunst, Andrew Padilla, and Joye Vaught. Do you know any of the 

Defendants on any basis, social, professional or otherwise?  YES  NO

If YES, please explain:

6. The Defendants are represented by their attorneys Paul Cambria, Erin McCampbell 

Paris, Thomas Bienert, Whitney Bernstein, Gary Lincenberg, Ariel Neuman, Gopi 

Panchapakesan, Bruce Feder, David Eisenberg and Joy Bertrand. Do you know 

any of the defense lawyers on any basis, social, professional or otherwise? 

 YES  NO

If YES, please explain:

7. The attorneys representing the United States are Kevin Rapp, Reginald Jones, 

Margaret Perlmeter, Peter Kozinets, Andrew Stone, and Daniel Boyle. The case 

agents are Internal Revenue Service Special Agent Richard Robinson and FBI 

Special Agent Desirae Tolhurst. Do you know any of the attorneys representing 

the United States or their case agents on any basis, social, professional or 

otherwise?  YES  NO

If YES, please explain:

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8. With the limited information you have been provided thus far, have you heard or 

read about, or do you know anything about, this case?  YES  NO

If YES, please explain what you have heard, read, or learned, and when and where 

you heard, read, or learned it:

BACKGROUND

9. Full name:

10. Age:

11. Gender: 

12. Residence: County: ________________ City: 

Zip code: __________ Years there: _______ Years in Arizona: _________ 

13. Race/Ethnicity (check all that apply):

 Caucasian  Hispanic/Latino  African American/Black

 Asian  South Asian (Indian Subcontinent)

 Native Hawaiian/Pacific Islander  Native American/Alaska Native

 Other (please specify) 

14. Marital Status: (check all that apply):

 Single, never married  Married  Living with partner  Widowed

 Divorced  Separated  Other

THE COVID-19 HEALTH EMERGENCY

15. Have you been tested for COVID-19? (Check all that apply.)

 YES, a PCR/diagnosis test  YES, an antibody test  NO 

If YES, when were you tested and what was the result of the test? 

Date of test: _______ Results:

16. Have you been diagnosed or assessed presumptively positive for COVID-19 but 

were unable to confirm the diagnosis with a test?  YES  NO 

If YES, when were you ill? 

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17. Have you been in close contact with anyone who has been diagnosed with a COVID19 infection or who is at risk of contracting COVID-19 (such as a medical provider, 

transportation worker, or food provider) within the last two weeks? 

 YES  NO

If YES, what was nature of your contact with the infected person? 

18. At any time over the past two weeks, have you developed flu-like symptoms such 

as a cough, fever, shortness of breath, or a loss of the sense of smell or taste? 

 YES  NO 

If YES, please describe: 

19. Are you a healthcare worker directly involved with the treatment of COVID-19? 

 YES  NO 

If YES, please describe: 

20. Are you over the age of 65 or a person with a serious underlying medical conditio n 

that places you at higher risk for severe illness from COVID-19 as defined by the 

Centers for Disease Control?  YES  NO 

If YES, check all that apply.

 > 65 years old  Reside in nursing home or long-term care facility 

 Chronic lung disease  Moderate to severe asthma  Severe heart condition

 Severe obesity (BMI > 40)  Diabetes  Chronic Kidney Disease

 Liver Disease  Immunocompromised, specifically:

 Pregnancy  Other: 

21. Do you reside with anyone who is over the age of 65 or with a serious underlying 

medical condition that would place them at higher risk for severe illness from 

COVID-19 as defined by the Centers of Disease Control?  YES  NO

If YES, check all that apply to the at-risk person with whom you reside.

 > 65 years old  Reside in nursing home or long-term care facility

 Chronic lung disease  Moderate to severe asthma  Severe heart condition

 Severe obesity (BMI > 40)  Diabetes  Chronic Kidney Disease

 Liver Disease  Immunocompromised, specify: 

 Pregnancy  Other: 

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22. Do you have any health or safety concerns about being a juror for the duration of 

this trial over the next three months? 

 YES  NO 

If YES, please describe: 

23. The trial will take place at the Sandra Day O’Connor United States Courthouse, 401 

West Washington Street, Phoenix, Arizona 85003. If selected, how would you 

report for jury service each day? (Check all that may apply).

 Drive my own car (alone)

 Drive/Carpool with people in my household

 Drive/Carpool with people outside of my household 

 Public Transportation  Taxi or Ride Share (Uber/Lyft) 

 Walk or Bike  Other: 

24. Do you agree to, and are you comfortable with, wearing a mask at all times in the 

courthouse (including in the courtroom, bathrooms, jury rooms, etc.)?

 YES  NO 

OCCUPATION, EDUCATION AND TRAINING

25. What is your current employment status? (Check all that apply).

 Employed full-time  Employed part-time  Student 

 Homemaker  Retired  Disabled  Unemployed

26. If employed, where do you work?

a. Job Title: 

b. Employer: 

c. Years there: 

d. Your duties: 

e. If you are currently unemployed, retired or disabled, list your prior occupatio ns:

27. What is your highest level of education completed? (Check one).

  Less than high school (Grade: ___ )  High school/GED  Technical school 

  2-year Associate’s degree  4-year Bachelor’s degree

  Master’s or Doctoral degree (list area of study):

  Other (please explain):

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a. List any degrees, licenses, or certifications you have: 

b. Are you currently a student?  YES  NO 

If YES, what is your area of study? 

28. If married or partnered, what kind of work does your spouse/partner do? If he/she 

is unemployed/retired, what kind of work did he/she do most recently?)

29. If you have children, please state their ages and, if they work, the occupation of 

each. Do not provide names.

 

 

 

30. Have you or anyone close to you ever worked for a governmental or public agency? 

 YES  NO 

If YES: 

Who:

Which agency(ies):

What years?

Job duties:

MILITARY SERVICE

31. Have you, a spouse or partner, or a close family member ever served in the 

military/armed forces, including the Reserves, State or National Guard, or ROTC? 

 YES  NO

If YES, answer the questions in the table below:

Who Branch Duties Dates of 

Service

Combat 

(Y/N)

Place of Service

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32. Were you ever involved in any way with military law enforcement, non-judicial 

punishment, military investigation, court martial, or administrative board or 

hearings?  YES  NO 

If YES, please explain: 

__________________________________________________________________

__________________________________________________________________

PRIOR JURY SERVICE

33. Have you previously served on a jury?  YES  NO

If YES, please state:

When,

Where?

Civil or 

Criminal?

Type of case (DUI, 

assault, personal 

injury, business 

dispute, contract, 

etc.)

Did the jury reach 

a verdict? 

If yes, what was 

the verdict?

Were you the 

foreperson?

a. Do you feel the justice system worked properly and fairly in each of those cases? 

 YES  NO 

Please explain:

34. Have you ever served on a grand jury?  YES  NO 

If YES, when and where? 

If YES, were you the foreperson?  YES  NO 

 

LEGAL AND CRIMINAL JUSTICE SYSTEM

35. Have you, any members of your family, or close friends1 ever been ARRESTED, 

CHARGED with, or CONVICTED of a crime (excluding minor traffic 

offenses)? (Check all that apply)

 YES, Arrested  YES, Charged  YES, Convicted  NO 

a. If YES, who? (do not provide names; just the relation to you)

 

1. For questions referencing family members or close friends, those terms mean any person 

with whom you have a close relationship so that their presence or role in your life could have an 

impact on, influence, or shape your thoughts, opinions, beliefs and judgment. 

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b. What crime(s)?

c. When and where? 

d. Was there a trial?  YES  NO 

e. If arrested, charged and/or convicted, do you, your family members or close 

friends feel like they were treated fairly by law enforcement and the criminal 

justice system?  YES  NO 

If NO, explain: 

 

f. Do you think this experience would impact your ability to be fair and impartial 

in this case?  YES  NO 

If YES, explain: 

 

36. Have you, any members of your family, or close friends ever been the VICTIM of 

a crime, regardless of whether it was reported to law enforcement authorities? 

 YES  NO 

a. If YES, who? (do not provide names; just the relation to you) 

b. What crime(s)?

c. When and where? 

d. Was it reported to law enforcement?  YES  NO 

e. If YES, was anyone caught or arrested?  YES  NO 

f. Were charges filed?  YES  NO

g. Were there any convictions?  YES  NO

h. Did you attend any court hearings (trial/sentencing)?  YES  NO

i. If the crime was reported, how did you, your family members, or close friend s

feel about the response of law enforcement in that case?

 

j. If the matter went to court, did you, your family members, or close friends feel 

like you were treated fairly by the courts and the criminal justice system? 

 YES  NO 

If NO, please explain: 

k. Do you think this experience would impact your ability to be fair and impartial 

in this case?  YES  NO 

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If YES, please explain: 

 

37. Have you, any member of your family, or close friends ever been a WITNESS to 

a crime, regardless of whether it was reported to law enforcement authorities? 

 YES  NO 

a. If YES, who? (do not provide names; just the relation to you) 

b. What crime(s)?

c. When and where?

d. Was it reported to law enforcement?  YES  NO  DON’T KNOW 

e. Did law enforcement take your statement or ask you any questions? 

 YES  NO 

f. Was the crime prosecuted?  YES  NO  I DON’T KNOW 

g. Did you testify in court?  YES  NO

h. If there was a police investigation and prosecution, did you, your family 

members, or close friends feel like you were treated fairly by the police, the

courts and the criminal justice system?  YES  NO

i. Do you think this experience would impact your ability to be fair and impartial 

in this case?  YES  NO 

 If YES, please explain: 

 

38. Have you, any members of your family, or close friends had any administrative 

problems with the United States government (for example, audited by the IRS; 

immigration proceedings; defaulted on a government loan)?  YES  NO 

If YES, please explain the issue and how it resolved. 

 

 

a. Do you think this experience would prevent you from being fair and impartial 

juror in this case?  YES  NO 

If YES, please explain: 

 

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39. Have you, any member of your family, or close friends ever applied or volunteered 

for any position in LAW ENFORCEMENT or served in the capacity of a law 

enforcement officer? By law enforcement officer, I am including not only state 

and local police officers, sheriffs and troopers, but also military police, volunteer 

police organizations, probation/parole officers as well as federal law enforcement 

agencies such as the Federal Bureau of Investigation (FBI), Drug Enforcement 

Administration (DEA), United States Citizenship and Immigration Services 

(USCIS), Homeland Security Investigations (HSI/ICE), United States Postal 

Inspectors Service (USPIS) and the Internal Revenue Service Crimina l 

Investigation Division (IRS). [Government objects to United States Citizenship 

and Immigration Services and ICE. Defense object to replacing USCIS and 

ICE with Homeland Security Investigation]

 YES, SELF  YES, FAMILY  YES, FRIEND  NO 

If YES:

a. Please indicate who, when and where they served and what their duties were: 

 

 

b. Is there anything about your service or your relationship with the person who 

serve(s) or serve(d) that would prevent you from being fair and impartial in this 

case?  YES  NO 

If YES, please explain (do not provide names; just the relation to you): 

 

40. Have you, any members of your family, or close friends ever been a PLAINTIFF, 

DEFENDANT or WITNESS in a court case? (Check all that apply.) 

 YES, Plaintiff  YES, Defendant  YES, Witness  NO 

If YES:

a. Please explain (1) the type of case, (2) what it involved, (3) your or their role in 

the case (plaintiff, defendant, witness), and (4) the outcome. 

(1) 

(2) 

(3) 

(4) 

b. Do you think this experience would prevent you from being fair and impartial in 

this case? 

 YES  NO 

41. Have you, any members of your family, or close friends ever testified in a court 

proceeding (civil, family, criminal, etc.?)  YES  NO 

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If YES, please explain the type of case (civil, criminal, family, etc.) and your role 

(plaintiff, defendant, witness, victim, other interested party). If you testified as an 

expert witness, please list your area of expertise (accountant, psychologist, chemist, 

etc.). [Defendants object to the use of the word “victim.” The government 

objects to the use of the phrase “other interested party” as a substitution for 

“victim.”] 

 

 

Do you think this experience would prevent you from being fair and impartial in 

this case?  YES  NO 

If YES, please explain: 

 

42. Have you followed any criminal cases or trials in the news or the media within the 

last five years or so?  YES  NO 

If YES: 

a. Which criminal cases or trials did you follow?

 

b. If you formed any opinions about the criminal justice system as a result of 

reading or watching any coverage of these cases or trials, please explain: 

43. How much do you agree or disagree with the following statements: (Answer each.) 

a. A defendant in a criminal trial should be required to prove his or her innocence. 

 Agree Strongly  Agree Somewhat 

 Disagree Strongly  Disagree Somewhat

b. The criminal justice system makes it too hard for the prosecution to convict 

people accused of crimes. 

 Agree Strongly  Agree Somewhat 

 Disagree Strongly  Disagree Somewhat

c. I would expect a person charged with a crime to testify in their own defense. 

 Agree Strongly  Agree Somewhat 

 Disagree Strongly  Disagree Somewhat

44. Do you know any attorneys (not already identified) on any basis, social, 

professional or otherwise?  YES  NO

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If YES, please explain, including if the attorneys represent plaintiffs, defendants, 

or the government:

EDUCATION, SPECIALIZED TRAINING OR EXPERIENCE

45. Have you, any members of your family, or close friends studied or practiced law or 

had any legal training?  YES, SELF  YES, OTHER  NO 

If YES, please explain who and the type of training or experience received

(paralegal studies, law degree, criminal justice studies, judiciary, courtroom staff

etc.) If you, any members of your family, or close friends are an attorney, please 

say who is (don’t use names; just the relation to you) and state the area of law that 

is practiced. 

 

46. Have you, any members of your family, or close friends studied, received training, 

or had experience in any of the following fields? (ANSWER FOR EACH AND 

CHECK ALL THAT APPLY.)

a. Advertising or marketing  YES, Self  YES, Other  NO

b. Banking or accounting  YES, Self  YES, Other  NO

c. Journalism or media  YES, Self  YES, Other  NO

d. Mental health or social work  YES, Self  YES, Other  NO

e. Ministry  YES, Self  YES, Other  NO

f. Women’s studies/rights  YES, Self  YES, Other  NO

g. Victim’s rights  YES, Self  YES, Other  NO

h. Online social media or website/

content development  YES, Self  YES, Other  NO

If YES TO ANY ABOVE, please explain who and the type of training or experience 

received. 

 

 

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47. On a scale of 1-10, rate your level of proficiency with technology. [(1)-I do not 

know how to use a computer through (10)-expert]. 

a. How many hours a day, on average, do you spend on your computer (work and 

leisure)?

b. Have you ever made a purchase of any kind from the Internet?

 YES  NO 

c. Have you ever placed an ad, comment, or review on a site on the Internet?

 YES  NO 

If YES, please generally explain. 

48. Have you, any members of your family, or close friends ever owned, started up, or 

held a significant role in the growth, development, and management of a business? 

 YES, SELF  YES, FAMILY  YES, FRIENDS  NO 

If YES, please explain. 

 

If you answered YES to the above question, please answer the following three 

follow-up questions:

a. Have you ever loaned or borrowed money to start a business?

 YES, loaned money  YES, borrowed money  NO

If YES, please explain:

b. If you have ever sold a business, did you have any oversight or rights over the 

business after you sold it?  YES  NO  NOT APPLICABLE

If YES, please explain. 

c. If you have ever bought a business, did the former owner, bank, or loan issuer

have any oversight or rights over the business after you purchased it? 

 YES  NO  NOT APPLICABLE

If YES, please explain. 

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49. Do you, any members of your family, or close friends have any experience using or 

investing in virtual currencies or cryptocurrencies, for example, Bitcoin, Bitcoin 

Cash, Litecoin or Ethereum or payment platforms for cryptocurrencies such as 

Bitpay or Gocoin?  YES, SELF  YES, OTHER  NO 

If YES, please explain. 

 

 

50. Do you, any members of your family, or close friends support, volunteer, donate to,

or work for any groups or organizations that advocate for Human Trafficking 

Awareness, Sex Trafficking Awareness, Victims or the Prevention of the Sexual 

Exploitation of Women? [Defendants object to use of the term “victims” here.]

 YES  NO 

If YES, please explain. 

 

 

 

51. Have you, any members of your family, or close friends ever watched films or 

documentaries, or read, written, discussed, or reported anything concerning any of 

the following: (ANSWER FOR EACH.) [Defendants object to the inclusion of 

the term “child exploitation”]

a. The #MeToo movement  YES  NO

b. Prostitution  YES  NO

c. Sex trafficking  YES  NO

d. Human trafficking  YES  NO

e. Child exploitation  YES  NO

If YES FOR ANY, please explain. 

 

 

52. Do you, any members of your family, or close friends support, volunteer, donate to,

or work for any groups or organizations that advocates for the legalization of 

prostitution or support the activities of sex workers?  YES  NO 

If YES, please explain. 

 

 

 

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53. Do you, any members of your family, or close friends support, volunteer, donate to,

belong to or work for any groups or organizations that advocate for the Freedom of 

Speech or First Amendment Rights, Internet Rights, or Media Rights (for example, 

the American Civil Liberties Union (ACLU)?  YES  NO 

If YES, please explain. 

 

 

PERSONAL INTERESTS AND LEISURE

54. List all religious, educational, social justice, civic, social, fraternal, union or 

professional organizations that you belong to or participate in.

 

55. What do you like to do in your spare time?

56. What type of books or publications do you like to read?

57. From what sources do you generally get your news? (Check all that apply):

 Online newspapers  Hard copy newspapers  Television 

 Radio  Magazines  Internet  Social media 

 Twitter  Friends & Family  Facebook

 I never follow the news  Other source (specify): 

a. Please list the name of the source(s) you’ve indicated above (for example, The 

Arizona Republic/AzCentral, Phoenix New Times, Village Voice, One America 

News, New York Times, Washington Post, Frontline, FOX, MSNBC, CNN, NPR, 

The Blaze, Christian Radio or any radio talk shows, or social media platforms): 

58. Do you watch television shows depicting law enforcement or the courts/judicial 

system (for example, CSI, Law & Order, NCIS, America’s Most Wanted, 48 

HOURS, Dateline, 20/20, Forensic Files, Cold Case Files, American Justice, 

American Greed, or any crime documentary series, etc.)?  YES  NO 

If YES, which shows do you watch? 

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59. Based on the programs you have seen, if selected for jury service, do you believe 

your service will be similar to what you have seen on television? For example, do 

you expect the government prosecutors and/or the defense attorneys and defendants 

at trial to be depicted or characterized in the same ways you’ve seen them in the 

programs you watch? 

 YES  NO 

Comments:

60. What radio stations or radio programs, if any, do you listen to on a regular basis?

 

61. Which social networking or media sites do you use? (Check all that apply).

 Facebook  Twitter  Instagram  Snapchat  TikTok

 LinkedIn  Pinterest  Reddit  Other: 

 NextDoor  I do not use social media

If you participate in social groups on any of these sites, please list which groups:

PROSTITUTION AND ADULT-ORIENTED ENTERTAINMENT

62. Do you have strong feelings about pornography on the Internet, or have you or 

someone close to you ever been affected by pornography? (Check all that apply.) 

 YES  NO

If YES, please explain: 

63. Do you have strong feelings about escort services or people working in the legal 

adult entertainment industry or have you or someone close to you ever been affected 

by this type of service?  YES  NO

[Government objects to the use ofthe term “escort services.”]

If YES, please explain: 

 

64. Does it bother you that adult escort services are legal and/or that people working in 

this industry can legally advertise their services?  YES  NO

[Government objects]

If YES, please explain: 

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65. Do you have strong feelings about prostitution, or have you or someone close to you 

ever been affected by prostitution or the purchase or sale of a sex act for money

(also referred to as “commercial sex”)?  YES  NO

If YES, please explain: 

66. Do you think law enforcement (local, state or federal) and the government (local, 

state or federal) should expend their resources investigating and prosecuting 

individuals who are purchasers of commercial sex?  YES  NO

Please explain your answer. 

67. Do you believe that prostitution should be legalized?  YES  NO

[Defendants object]

Please explain your answer. 

68. Do you think law enforcement should expend government resources investigating 

and prosecuting individuals who engage in child prostitution or the sex trafficking 

of children?  YES  NO [Defendants object to references to “child 

prostitution” or “trafficking of children”]

Please explain your answer. 

69. Do you think law enforcement agencies should expend government resources 

investigating and prosecuting businesses or individuals who provide a platform that 

sell goods or services that promote or facilitate prostitution?  YES  NO

Please explain your answer. 

70. Have you, any members of your family, or close friends ever engaged in, been 

accused of engaging in, or been convicted of prostitution, soliciting prostitution, or 

any act related to the purchase of commercial sex?  YES  NO

If YES, would that experience prevent you from being a fair and impartial juror in 

this case?  YES  NO 

If YES, please explain your answer. 

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71. Have you, any members of your family, or close friends ever engaged in, been 

accused of engaging in, or convicted of sex trafficking or sex related crimes?

 YES  NO

If YES, would that experience prevent you from being a fair and impartial juror in 

this case?  YES  NO 

If YES, please explain your answer. 

CASE SPECIFIC QUESTIONS

72. Prior to filling out this questionnaire, had you heard of the website 

www.backpage.com?  YES  NO

73. Have you, any members of your family, or close friends ever used 

www.backpage.com?  YES  NO 

If YES: 

For what purpose? 

What sections did you use?

74. Have you, any members of your family, or close friends ever visited an online 

classified website such as www.craiglist.org, www.ebay.com, www.oodle.com, or 

other online classified websites?  YES  NO 

If YES: 

Which website:

For what purpose?

What sections did you use?

75. In general, what are your feelings about the laws and regulations affecting the 

internet, including the publishing of content posted by users of the websites? 

76. What are your feelings about whether websites (such as YouTube, Facebook, 

Twitter, Google, and Instagram, among others) should be responsible for the content 

posted by users of the websites? 

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77. Have you, any members of your family, or close friends ever used an adult-oriented 

dating or connection service (for example, Tinder, Bumble, Hinge, Ship 

(getshipped), OkCupid, PlentyofFish, AdultFriendFinder, iHookup, 

AshleyMadison, NoStringsAttached, BeNaughty, GetItOn, MaritalAffair, Alt,

Grindr, Pure, Match)? 

 YES  NO

If YES, please explain who (don’t use names) and identify which services:

78. Do you have any strong feelings about tattoos or people who have tattoos? 

 YES  NO

If YES, please explain:

79. This case will involve testimony regarding sexually explicit topics. Words and 

phrases such as oral sex, anal sex, blow job, penis, and vagina may be used 

throughout this trial. Victims and witnesses may testify about their experiences 

with prostitution, child sex trafficking, and may describe their experiences using 

vulgar or sexually-graphic language. Sexually provocative images of victims and 

witnesses may be introduced into evidence. If chosen as a juror, you must be able 

to discuss the evidence and these sexually explicit topics with your fellow jurors as 

you deliberate on the evidence. [Defendants object to use of the terms “victim”

and “child” in this context.]

Will you be able to deliberate on the evidence, knowing that it requires discussio n 

over topics of a sexual nature?  YES  NO  NOT SURE

Please explain: 

80. The nature of some of the charges that have been brought in this case involve claims 

of facilitating or promoting business enterprises involved in prostitution and money 

laundering. Is there anything about these subjects that would make it difficult for 

you to be fair and impartial in this case?  YES  NO 

If YES, please explain: 

VICTIMS AND WITNESSES

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[Defense objects to inclusion of the word “victim”]

81. Part of your role as a juror is to determine the facts of the case, including evaluating 

the credibility or believability of witnesses. Do you believe you can determine 

whether a person is (or is not) credible or believable?  YES  NO 

Please explain: 

82. Would you prejudge a witness or the case, even in the slightest way, if one or more 

of the parties, attorneys, or witnesses comes from a particular national, racial, ethnic, 

or religious group, or has a lifestyle different than your own? [Government objects

and proposes Question 83]

 YES  NO 

Please explain:

83. Some of the victims and witnesses in this case are ethnic minorities. Would you 

find a victim or witness’s testimony to be more or less credible simply based on 

their race, nationality, ethnicity or religion? [Defendants objects for the 

following reasons: (1) to the word “victim”, duplicative to Question 82, and (3) 

argumentative]

 YES  NO 

Please explain:

84. Some of the victims and witnesses in this case are ethnic minorities and of a low 

socio-economic status. Would you find a victim or witness’s testimony to be more 

or less credible simply based on their socio-economic status? [Defendants objects 

to the word “victim” and as argumentative]

 YES  NO 

Please explain:

85. Some of the victims and witnesses in this case have experienced challenges with 

substance abuse and homelessness. Would you find a victim or witness’s testimo ny 

to be less credible simply based on their experiences with substance abuse (drug or 

alcohol abuse) and homelessness? [Defendants object to the word “victim”]

 YES  NO 

Please explain:

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86. Are you familiar with implicit biases, which occur without conscious awareness? 

 YES  NO

If YES, what techniques work to reduce such bias within yourself? 

FINAL QUESTIONS

87. The Court will instruct you on the applicable law at the conclusion of the case. If 

selected as a juror, you will take an oath to follow the law, even if you disagree with 

it. Will you follow the instructions and the law as it is provided to you even if you 

disagree with it?  YES  NO 

88. Understanding that jury service is an honor as well as a duty, is there any reason

why you would prefer not to serve as a juror in this case? This could include any 

situation at home or on the job, issues in your life and/or stressful or anxietyproducing life events, such as divorce, health, abuse, bankruptcy, moving, etc. 

 YES  NO 

If YES, please explain:

89. Do you have any religious, moral, spiritual or philosophical beliefs that would make 

it difficult for you sit in judgment of another person?  YES  NO 

90. Is there any other information you feel the judge or attorneys should know about 

you, including any reason why either side (the government or the defense) may not 

want you to serve as a juror in this case?  YES  NO 

If YES, please explain:

91. Is there anything you wish to discuss with me and the attorneys in private, outside 

the presence of the other jurors?  YES  NO

IF YES, please describe below. 

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I declare, under penalty of perjury, that all answers are true and correct to the best of my 

knowledge.

 

SIGNATURE DATE 

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EXPLANATION SHEET

If you were unable to sufficiently answer any question in the spaces provided, please use this area 

to complete your answer. Please indicate the question number(s) from the questionnaire associated 

with any comment(s) you make below.

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