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Gregory J. Kuykendall, Bar # 012508

Amy P. Knight, Bar # 031374

KUYKENDALL & ASSOCIATES

531 S Convent Avenue

Tucson, AZ 85701

(520) 792-8033

greg@kuykendall-law.com

amyknight@kuykendall-law.com

Attorneys for Defendant Scott Daniel Warren

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America,

Plaintiff,

vs.

SCOTT DANIEL WARREN,

Defendant.

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No. 18-cr-00223-RCC(DTF)

DEFENDANT’S PROPOSED VOIR 

DIRE QUESTIONS

Defendant Dr. Scott Daniel Warren respectfully submits the following 

proposed voir dire questions:

1. Summary of Charges: The Government has charged the defendant, Dr. Scott 

Daniel Warren, with harboring two young men who had crossed into this country 

without authorization at a humanitarian aid base camp in Ajo, Arizona known 

as the Barn. It has also charged him with conspiring to transport and harbor these 

same two individuals. Dr. Warren contends that any actions he undertook 

regarding these two individuals were limited to the provision of humanitarian 

aid.

2. Do any of you think, as we sit here right now, that if the government has charged 

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the defendant with a crime, he must have done something wrong? 

3. If you were asked to vote right now on whether the defendant is guilty of the 

charged crimes, how many of you would vote that he is guilty?

4. How many of you enjoy watching TV shows about criminal investigation, like 

CSI or Forensic Files? 

a. Which shows do you watch? How often? Why do you like them?

b. How many of you enjoy listening to investigation podcasts like Serial or 

In the Dark? 

5. Who here has strong feelings about law enforcement officers?

a. Has anybody here ever worked in law enforcement?

b. Does anybody have close friends or family in law enforcement?

c. Does anybody have any yard signs or bumper stickers or similar displays 

with a pro-law enforcement message, such as “Thank a Cop” or “Blue 

Lives Matter?” 

d. Does anybody belong to any social media groups or “like” any social 

media pages with messages like “Thank a Cop” or “Blue Lives Matter?” 

6. How many of you have ever supported a group that advocates for stronger border 

security? 

a. Have you ever attended meetings, marches, or rallies about this cause? 

b. Have you ever contacted your elected representatives about border 

security?

c. Have you ever written or published anything, including blog and social 

media posts, advocating stronger border security?

d. Do you have any bumper stickers, yard signs, or other displays advocating 

more border security, with messages like “Build that Wall” or something 

similar?

e. Do you belong to any social media groups or “like” any social media 

pages that advocate for strong border security?

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7. How many of you believe that U.S. citizens are obligated to report the presence 

of illegal aliens to law enforcement?

a. How do you feel about the fact that the law does not generally require 

anyone to report known or suspected crimes to law enforcement?

b. If I instruct you that there is no legal obligation whatsoever for a citizen 

to report the presence of aliens to law enforcement, will you follow that 

instruction?

8. How many of you believe that it is against the law to give people who may 

choose to cross into the U.S. illegally information about the dangers of doing so?

a. How do you feel about educating people about the dangers they could face 

while crossing?

b. Can and will you follow my instructions that it violates no law to provide 

this type of safety education?

9. How many of you believe that people who crossed illegally into the United 

States do not have Constitutional rights?

a. How many of you believe that it is against the law to inform people who 

may choose to cross into the U.S. illegally of their rights?

b. How do you feel about educating people who may choose to break the law 

by entering the U.S. illegally about what their rights are?

c. Can and will you follow my instructions that it is not illegal to inform

people who may later choose to enter the U.S. illegally about what their 

rights are?

10.How many of you believe it is against the law to provide people who may cross 

into the U.S. illegally with survival tools like chlorine to put in water, or combs 

to remove cactus spines?

11.How many of you believe that people who choose to break the law deserve to 

suffer the consequences? 

12. Who here believes that people walking across the desert should be left unaided, 

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even if they are in danger, because they made the choice to enter the U.S. 

illegally? 

13. How many of you believe that putting water out in the desert for migrants is 

wrong?

14. How many you believe that putting other supplies in the desert for migrants —

like food or blankets — wrong?

15.Who here believes that if a person associates with a criminal, then that person 

has also committed a crime?

16. Have any of you ever had a negative experience interacting with an 

undocumented immigrant?

17. How many of you speak or understand Spanish? 

a. How did you learn Spanish?

18. How many of you have ever gone hiking in the desert? 

Dated this 23rd day of May, 2019

KUYKENDALL & ASSOCIATES

By /s/ Amy P. Knight________

Gregory J. Kuykendall

Amy P. Knight

531 S Convent Avenue

Tucson, AZ 85701

Attorneys for Defendant Scott 

Daniel Warren

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CERTIFICATE OF SERVICE

I certify that on May 23rd, 2019, I electronically transmitted a PDF version 

of this document to the Clerk of Court using the CM/ECF System for filing and for 

transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: 

Nathaniel J. Walters, Esq. (email: Nathaniel.walters@usdoj.gov) 

Anna R. Wright, Esq. (email: anna.wright@usdoj.gov) 

United States Attorney’s Office 

405 W. Congress, Suite 4800 

Tucson, AZ 85701

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