EXHIBIT A

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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) transactional 

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 participation 

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

begin February 9 through February 11, 2022, and will resume February 22, and

continue through May 6, 2022. Trial will take place each day from 9:00 a.m. to 

4:30 p.m. Tuesday through Friday, and trial will be held on some Mondays. There 

will be a break for lunch as well as a short mid-morning and mid-afternoon break. 

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 and age of dependent(s):

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. Age:

10. Gender: 

11. Residence: County: ________________ City: 

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

12. 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) 

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

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

 Divorced  Separated  Other

COVID-19

14. Have you been tested for COVID-19 within the last 14 days? (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:

15. 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? 

PROPOSED EDIT: The United States has no objection to the removal of this 

question. The original jury questionnaire was drafted during the first months of the

pandemic when testing was not available as it is now. Today, testing is widely 

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available at pharmacies, doctor’s offices, groceries stores and even at-home testing 

kits. 

16. 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? 

17. 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: 

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

 YES  NO 

If YES, please describe: 

19. Are you over the age of 65 or a person with a serious underlying medical condition 

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: 

PROPOSED EDIT: The United States has no objection to the removal of this 

question. The original jury questionnaire was drafted during the first months of the 

pandemic. Since then, vaccines have been developed and become widely available 

in the United States. In the recent days, a pharmaceutical company applied for 

emergency use authorization for a Covid-19 pill. If a juror wishes to inform the 

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Court about his or her concerns over Covid-19, or any other health or safety concern, 

he or she may do so in Question 21. 

20. 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: 

PROPOSED EDIT: The United States has no objection to the removal of this 

question. The original jury questionnaire was drafted during the first months of the 

pandemic. Since then, vaccines have been developed and become widely available 

in the United States. In the recent days, a pharmaceutical company applied for 

emergency use authorization for a Covid-19 pill. If a juror wishes to inform the 

Court about his or her concerns over Covid-19, or any other health or safety concern, 

he or she may do so in Question 21. 

21. 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: 

22. 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: 

23. 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.)?

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 YES  NO 

OCCUPATION, EDUCATION AND TRAINING

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

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

 Homemaker  Retired  Disabled  Unemployed

25. 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 occupations:

26. 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):

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? 

27. 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?)

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

Do not provide names.

 

 

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

 YES  NO 

If YES: 

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Who:

Which agency(ies):

What years?

Job duties:

MILITARY SERVICE

30. 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

31. 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

32. 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?

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

 YES  NO 

Please explain:

33. 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

34. Have you, any members of your family, or close friends 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)

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: 

 

35. 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 

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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 friends

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 

If YES, please explain: 

 

36. 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: 

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37. 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: 

 

38. 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 Criminal 

Investigation Division (IRS).

 YES  NO 

PROPOSED EDIT: REMOVE separate boxes for “ YES, Self,  YES, Family, 

and  YES, Friend” as duplicative to Question 38(a). 

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): 

 

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39. Apart from cases discussed in your answers to Questions 35, 36 and 37 above, 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  NO 

PROPOSED EDITS: Add language: “Apart from cases discussed in your answers 

to Questions 35, 36, and 37 above” to avoid duplicate responses and remove 

separate boxes for “ YES, Plaintiff,  YES, Defendant, and  YES, Witness” as 

duplicative to Question 39(a)(3)).

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 

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

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

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.).

 

 

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

this case?  YES  NO 

If YES, please explain: 

 

41. 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?

 

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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: 

42. PROPOSED PARAGAPH: In a criminal case, the defendant has the presumption 

of innocence. This means the defendant is presumed innocent unless the United 

States proves the defendant’s guilt beyond a reasonable doubt. Because the United 

States bears the burden of proof beyond a reasonable doubt this means a defendant 

has the right to remain silent and never has to prove innocence or present any 

evidence. 

ORIGINAL PARAGRAPH: The law requires the Government to prove the 

defendant guilty beyond a reasonable doubt. This means that the defendant is not 

required to produce any evidence or to prove innocence. A defendant also has a 

right not to testify and the exercise of that right could not be used against a defendant 

or considered by a jury.

RATIONAL: Slightly rephrased for clarity.

a. Do you understand these principles of law?

 YES  NO 

b. Do you agree with these principles of law?

 YES  NO 

c. PROPOSED Question 42(c): If chosen as a juror, the Court will instruct you on 

the applicable law for this case and you will be required to follow the Court’s 

instructions. Will you be able to follow the law as it is instructed by the Court, 

even if you disagree with it?

 YES  NO 

PROPOSED EDIT: Proposed Question 42(c) moves Question 86 from the end of 

the original jury questionnaire up to this section of the proposed jury questionnaire. 

During voir dire, several prospective jurors indicated they found this section of 

questions confusing and counsel for both the United States and defense spent a 

considerable amount of time following up on several jurors’ responses to Questions 

42 and 43. 

43. Do you agree or disagree with the following statements:

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

people accused of crimes.

 Agree  Disagree 

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

 Agree  Disagree 

PROPOSED EDIT: To simplify the question, the United States proposes 

eliminating “strongly disagree” and strongly agree” from the list of responses. 

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

professional or otherwise?  YES  NO

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

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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. 

 

 

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  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. 

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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. 

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, FAMILY  YES, FRIENDS  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, or the Prevention of the Sexual 

Exploitation of Women? 

 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.) 

a. The #MeToo movement  YES  NO

b. Prostitution  YES  NO

c. Sex trafficking  YES  NO

d. Human trafficking  YES  NO

If YES FOR ANY, please explain. 

 

 

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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. 

 

 

 

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): 

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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? 

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:

62. Do you, any members of your family, or close friends support or participate in any 

groups or organizations that focus on promoting social justice, political activism, or 

police or corporate accountability?  YES  NO

If YES, please explain: 

PROSTITUTION AND ADULT-ORIENTED ENTERTAINMENT

63. 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: 

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64. PROPOSED QUESTION: Do you have strong feelings about the adult 

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

the adult entertainment industry?  YES  NO

ORIGINAL QUESTION: 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

If YES, please explain: 

 

OBJECTION: The United States renews its objection to the use of the term “escort 

services.” First, as worded, the question lumps together “escort services” with “the 

legal adult entertainment industry” and is vague, confusing, and misleading. In 

common usage, “escort services,” particularly in the “adult” context – are often 

associated with prostitution (which is illegal). (See e.g., 

http://www.yourdictionary.com/escort-service (defining “escort service” as “[a] 

company that provides customers with companions or prostitutes for a fee”).) 

Second, inserting “legal” before “adult entertainment industry” is misleading 

because it suggests to the jurors that this Court believes the law states those who 

work in the “adult entertainment industry” are not engaging in commercial sex, 

prostitution, or otherwise violating the law. Third, while some states or localities 

regulate escorts through statutorily-defined licensing requirements, many others do 

not recognize or license “lawful” escorts. Fourth, the United States contends that 

the evidence at trial will show that the vast majority of Backpage.com’s “escort” 

ads were prostitution solicitations. Against this background, it is confusing and 

misleading to equate “escorts” with “people working in the legal adult entertainment 

industry.”

65. 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

If YES, please explain: 

OBJECTION: The United States renews its objections to this question and 

incorporates by reference the arguments made in Question 64. First, this question 

is vague, misleading, and confusing, because “escort services” (let alone “adult 

escort services”) are not recognized as lawful, legal services throughout the United 

States. Second, while some states or localities regulate escorts through statutorilydefined licensing requirements, many others do not. And many jurisdictions that 

permit licensed escorts regulate the manner in which escorts may advertise. (See, 

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e.g., A.R.S. § 9-500.10.A.1 (escort ads must include “[t]he escort license number of 

the escort if the advertisement is for the services of a specific escort”; Scottsdale 

City Code Sec. 16-470 (“All advertisements used by an escort...and likely to be 

seen by Scottsdale residents, shall contain the Scottsdale permit or license number 

of the permit or license holder.”).) Third, this question is also cumulative and 

duplicative to Question 64. 

66. 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: 

67. 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. 

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

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.craigslist.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. PROPOSED QUESTION: This case involves prostitution. Victims and 

witnesses will testify about their experiences being posted on backpage.com that 

resulted in their involvement in prostitution and sex trafficking. Words such as oral 

sex, anal sex, blow job, penis and vagina will be used as well as coded language, 

phrases and symbols related to prostitution, for example, greek, BBBJ, GFE, roses, 

HH, full service, and certain emojis will be used. Sexually provocative images will 

be introduced into evidence. If chosen as a juror, you must be able to discuss the 

evidence and these sexual topics with your fellow jurors as you deliberate on the 

evidence. 

ORIGINAL QUESTION: 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, sex-trafficking, and may describe their 

experiences using vulgar or sexually-graphic language. Sexually provocative 

images 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. 

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

about prostitution?  YES  NO  NOT SURE

Please explain: 

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RATIONAL: The proposed changes are designed to focus the jurors on the 

anticipated evidence involving prostitution. 

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

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. PROPOSED QUESTION: Some of the witnesses in this case are: (1) ethnic 

minorities, (2) of a low socio-economic status, or (3) have experienced challenges 

with substance abuse (alcohol and/or drugs). Would you find a witness’s testimony 

to be more or less credible simply based on their: (Answer for each)

(1) race, nationality, ethnicity, or religion:  YES  NO 

(2) low socio-economic status:  YES  NO 

(3) substance abuse (alcohol and/or drugs):  YES  NO 

 

ORIGINAL QUESTION: Some of the witnesses in this case are ethnic minorities. 

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

their race, nationality, ethnicity or religion? 

 YES  NO 

Please explain:

RATIONAL: For brevity, this proposed question seeks to combine Questions 82-

84 and removes homelessness from Question 84. 

83. Some of the witnesses in this case are ethnic minorities and of a low socio-economic 

status. Would you find a witness’s testimony to be more or less credible simply 

based on their low socio-economic status?  YES  NO

Please explain:

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PROPOSED EDIT: Question 83 may be removed if proposed changes to Question 

82 are granted. 

84. Some of the witnesses in this case have experienced challenges with substance 

abuse and homelessness. Would you find a witness’s testimony to be more or less 

credible simply based on their experiences with substance abuse (drug or alcohol 

abuse) and homelessness?  YES  NO 

Please explain:

PROPOSED EDIT: Question 84 may be removed if proposed changes to Question 

82 are granted.

85.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

 

86. PROPOSED EDIT: Original Question 86 has been moved to Proposed Question 

42(c). 

87. 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:

88. 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 

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89. 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:

90. 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. 

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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