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have to return fo5.7r th5.2is case altho5.2ugh you may be directed to go through a similar process in another case Others may be directed to return tomo6.3rrow8.5 an additional day this week if necessary5.5 And ultimately some of you will return fo5.6r th5.6e third and fina4.7l step in the proc4.7ess That will place on N8ovember In any even5.5t after you complete st ep of the process today you will receive instructions on next steps th at are particular to you As you know from my prior remarks to you and from the questionnaire were here today to selec5t-1 a ju6.2ry to serve in a crimin6.2al case calle the United States aga4.6i-1.4nst Ghislain5.8e Maxwell As you read in the questionnaire the Indictment alleges th at Ghislaine Maxwell conspired with and aided and a4.8b1etted Je4.8ff4re4.8y Epstein to6 entice min6o1r fema4.8les to travel to engage in criminal sex activ5.8ity to transpor3.8t min5.8o.8rs to engag5.8e-.4 in sexual activity and to ngage in sex trafficking of a minor Ms Maxwell has pled not guilty to all char ges Ms Maxwell is presumed innocent and before can be found guilty on any charge the ju5.8ry must find th5.8at the Governmen5.8t-1.4 has proven each element of that crime b5.7e4.5yond a reaso5.7n.7able doubt.5.7 Thank you for participating in this process Th process of selecting a jury in a criminal case is a critical part of jus tice The p5.8u.8rpose th5.8is proc ess is to select those juro5.2rs who5.2 Case Document Filed Page of can be and imp5.8artial to bo5.8th s5i3.6des in this case Some people find that they can be fair and impartial in one kind of case but for various reason rela5ted their own lif experien5.7ces or views cant be fair in another kind of case The proces4.5s that we us4.5e is designed to help us figure out whether you can be fair and imparti al to both sides in this case If during the course of th5.5is process y5.5ou come to believ6e-.2 that because s5.2o1meth6ing th6at you have ex5.6perien5.6ced or because someth5.6ing y5.6ou ve heard or read that you cannot be fair and impa4.4r-1.4tial?that is that y5.6ou woul favor either the overnment or the Defendant regardless of what the evidence shows?then you must tell me Its not unusual and theres no reason to be embarrassed about it But the sys5.1t3.7em only wor3.9k.9s if a4.7ll citizen5.9s are willing an5.5d prepared to serve as ju5.5rors when they can do so fairly and impartially I do not expect that anybody woul seek to avoid this important duty for any but the most compelling reasons.5.6 As I mentio5.9ned in my re4.7ma4.7rks the Court has taken a number of step5.7s to help ensure the process for selected jurors is as safe and easy5.5 as possib5.5l-1.7e We ha ve masking and distancing protoco5.8l-1.4s We have r3.8e-.4c4.6onfigured co5.8urtroo5.8ms to enhance me4.6asure4.6s0 The Court will provide transportation fo selected jurors to and from th courthouse each day Breakfast snacks and lunch will be provided for you And please note that yo5.7u are not req5.7u.7ired to be v5.6accinated to serve on th5.8e jury or required to disclose your vaccination status However if you are selected to return for the final phase of jury selectio5.6n a courtho5.6u.6se st aff member will as4.4k you before you leave today to fill out a form regard5.6ing yo5.6ur COVID-19 vaccinatio5.6n status If you are co5.6mfortab5.6l-1.6e d5.6i-1.6sclosing th5.6e information will solely used by co5.6urthouse to en sure compliance with the Dis4.5t-1.9rict?s COVID-19 distan5.7cing Th5.7e informatio5.7n will not provided to the attorney5.7s or anyone involved in Case Document Filed Page of the cas4.8e an5.6d the in5.6formation will no5.6t affect whether or not you are selected to serv6.3e a juro6.3r in this case Finally the form will be destroyed at the of tr4.2ial To conduct the next phase of the p5.3r-1.7ocess I will ask each of yo5.3u some questions individually We?ll do that in a separate where I a nd the lawyers and the D7.6e-.8fendant are sitting You all will be in th5.6e co5.6ur troo5.9m one4.7 at a time B7.9ear in mind that th5.9is is a public courtroom To prot ect your privacy I will only refe to you by your juror number Please do not state any identifyi ng information example if we talk about your job you could say that you are a sales cler at a large retail store without stating the specific name of your This is to protect yo5.4ur privacy Even with th5.6ose privacy protections in place if there is something that would be too difficult or embarrassing fo you to say on the public record please let me know And please keep in mind that if you are selected as a juror we will continue to refer to you only by your juror number throughout the process Now if you are selected as a juror your job is going to be to listen to the evidence and to my instructions on the law and to make a determina tion thats based only on the law I want to speak to you generally about so me things to keep in mind The first thing is as Ms Maxw ell sits here now shes presumed to be innocent She is presumed in5.6nocent until and only if the jury finds that sh5.7e is g5.7u.7ilty a reason5.7able doubt As I just explained to you shes been indicted fo a number of crimes but an indictment is just an accusatio5.8n It is no5.8t evidence and it doesn6t-1.4 me an that Ms Maxwell is guilty any5.7t-1.5hing You cant assu5.8me4.6 that sh5.8e is g5.8u.8ilty mo5.8re to guilty because sh5.8es been in an indictment and alleged to have committed th crimes charged with co mmitting thes4.9e crimes Thats the re4.7ason we have tr3.9ials to d5.9e-.3ter3.9mine whether the Government can prove a defendants guilt a reason5.6able doubt A defendan5.6t-1.6 in a cr iminal case does not have to pro5.4v.4e that she Case Document Filed Page of is not guilty That means a defendant does not have to testify or to put on any evidence and a juror against a de fend5.5ant if she makes that The next thing is that as jurors you must fo llow the law as I give it to you even if you dont agree with it or if you thi nk the law should be different You also have to base your verdict on the evidence not on somethi ng that youve read in the newspapers or the internet or seen on tele vision or heard about on social media or in discussions with friends family or colleagues And you cant base your decision in this case on something that you might have read or heard about another case As I said before there is si gnificant media interest in this case As jurors you are not permitted to read any news about this case ou cannot read or watch or listen to any accounts of this case at all If you see something in the paper or online youre just going to have to turn the page or close the brow ser You cant read it Equally important youre not permitted to di scuss this case with anyone else while the case is going on Even with your fellow jurors you cant discuss th case until youve heard all the evidence and I?ve given my instructions on the law Again thats because you can only consider the evidence that you hear in the courtroom not anythi ng outside of the courtroom You have to keep an open mind Nor may you discuss th case with friends or family until after your jury se4.5rvic4.5e is comp5.7lete You can tell y6.1ou are a juro6.1r in a in f4.1e4.9deral court and that the judge has told you that you are not permitted to say anything further Similarly u5.6n.6til you are excused jury rv5.7ice you cann5.7o.7t post any5.7t3.5hing about y5.7our experience as a juro5.4r on Facebook Twitter Ins4.6t-1.8agra TikTo5.6k.6 or any of social media Another instruction you cant look up or google or do any other kind of research or s5.6earch manner about anything related to the case or anyone involved in the case Case Document Filed Page of The reason for these rules as I am sure you unde rstand is they protect the integrity of the trial and both6.1 sides a fa4.9ir Jurors in case4.7s.1 base ve4.7rdic ts on the evidence th5.7at they h5.7ear in the courtroom not on something th at somebody else tells you not on something that you see on TV or on social media why if youre selected as a juror I5.3ll be reminding you of these rules regularly Y7.4ou cant watch news accounts look anything up or speak to anybody else about the case You would be violating the oath you have taken as jurors and you would be violating my orders if you were to do that Finally you must report to me through my ourt deputy any effort by any person to speak with you about the case or to in fluence you about the case or to get information about the case The attorneys and their assistants have been in structed by me not to speak to you or otherwise engage with you They are not being rude or indifferent They are merely following my instru5.9ctions.5.9 I do want to thank all of you for the time you ve invested already in this process Our system cannot function unless we have good people like you who are willing to give up their time and to serve as juro6rs.6 Please sit quietly until your number is called and you are br ought into the courtroom for questioning by me Please follow all the instru ctions of the courtroom staff Although you may use your electronic devices while you are wai ting bearing in mind of course all of my instructions that forbid you to do any research or engage in any communi cations about the case through any means you must tu rn off and hand over any electr onic devices to the Jury Department staff before you are brought into the courtroom I look fo5.7rward to meetin5.7g each of you in person soon Thank you Case Document Filed Page of DRAFT November6.1 UNITED DISTRICT DISTRIC-3.7T.1 OF NEW YOR-3.7K UNITED S-4.4T.2ATES OF AMERICA AJN GHISLAINE Defendant DRAFT E-3.5XAMINAT-3.5ION OF PROSPECTIVE JURORS-4.3 Case Document Filed Page of Introductio5.6n1.8 PLACEHOLDER INTRODUCTORY RE-5MARKS-7.8 Case Document Filed Page of INDIVIDUAL Ability to F6.3o.5llow Instr4.3u1.7ctions4.7 As I instructed you earlier one of th5.9e princ4.7i-1.3ples crimina4.7l-1.3 la4.7w is that a defendant in a criminal case is presumed to be innocent Like anyone accused of a crime in this country Ms Max6.3w3.5ell is and must be presumed innocent of any and all made against her un5.4less and until the Governmen5.4t-1.8 proves her guilt a reason5.4able doubt It is the Government?s burden to pr ove guilt beyond a reas onable doubt and the Government?s burden of proof alone The defendant ha no burden to prove her innocence to present any evidence Are you able to follow7.5 these instructions As I instructed you earlierI also instructed you earlier that u5.8n.8til you are excused this case you may not consume any media of any kind re ports of this case of any typeaboutof thisthe case of any kind time including social media research the case it in any mann5.5er or discuss th caseit with anyone.r ead listen to or watch any accounts of this case reported on television the radio or ove the Internet or soci al media Jurors are also not allowed to do any research regard ing this case whethe over the Intern6.1et on social media or in any other manner The case must be decided solely on the basis of the evidence in the4.7 courtroo5.9m Would you have any diff iculty following these rules which are binding on every juror When Since the time you filled out your questionnaire you instructed that you would have to follow these rules Have you done so anyway hHave you failed to follow these rules in any way Such as onsuming any social me dia googling the case or discussing it you seen any reports includ ing on social media googled the case or discussed the case with any pers on you were told not to rese arch read or watch anything Case Document Filed Page of about the case or learn anything abou the case Have you even though you were instructed not to do that done that anyway Have you looked things up on the internet even if you just Googled it If you have now is th time to tell me General Ab6.8ility to Serv5.6e On your questionnaire you stated that you do not have any unm ovable commitments between November and approximately January Does that continue to be accu5.4rate Prior Know7.4ledge of Ms Maxwell If Ju5.4ror HAS HEARD of Ms Maxw7.6ell In your questionn5.4aire you reported that you had heard of Ms Maxwell befo re starting this process Have you formed an opinion or heard read or seen anything about Ms Maxw ell that might make it difficult for you to be a fa4.8ir and6 impa4.8r-1tial ju6.4ror in this ca5.2se If Ju5.4ror HAS NOT heard of Ms Maxwell In yo5.6ur questionn5.6aire you rep5.6o.6rted that yo5.6u had not heard of Ms Maxwell before star ting this process Is that accurate Prior Know7.4ledge of Jeffrey Epstein If Ju5.3ror HAS HEARD of Epstein your questionnaire you5.3 reported that you had heard of Jeffrey Epstein before starting this process Have you formed an opinion or heard read or seen anything a bout Mr Epstein that might make it diff icult for you to be a fair and impartial juror in this If Ju5.4ror HAS NOT heard of Epstein5.4 In your qu5.3estionn5.3aire you reported5.3 that you had not heard Jeffrey Epstein befo5.6re ting this process Is that accu5.4rate Case Document Filed Page of Nature of Charges You reported in your questionnaire that ins ert question number of any YES answers for question or Would that experience affect your ability to serve as a fair and juro5.8r in this case Knowledge of the Tria5.7l Partic4.5ipant3.7s In the your questionnaire I listed th6e names of a4.8ll the trial pa4.8rticipan6ts an6d you indicated that you did not know any of those th5.7e trial par3.7t-1.5icipants ind5.7i-1.5viduals by name I?ll ask you to also look around now and let me know if you recognize anyone in the courtroom I will now re4.8ad aPlease r4ead this list of individuals who may be mentioned during the trial or who may be witnesses in this case Names to be supplied Do you know any of those people Have you had any dealings dir ectly or indi rectly with any of these individuals To your knowledge have any of your relatives friends or associates had any dealings ith any of these individuals Knowledge of Location Events in this case are alleged to have taken place at the fo llowing location5.5s-.3 to be s5.2upplied Are you particularly familiar with any of those locations Prior Jury Service For ju5.5rors who answered YES to q5.5u.5estion5.5 On your questionnai re you said that you have served as a juror In what court did you serve and was it a civil or criminal case Case Document Filed Page of What case was it Withou5.9t telling us what the was did th5.9e jury reach5.9 verdic5.2t For ju5.5rors who answered YES to q5.5u.5estion5.5 On your questionnai re you said that you have served as a grand ju ror When and where For jurors who answered YES to either question Is there a nything about your prior experience as a juror that would pr event you from acting as a fair and impartial juror in this Relationship with and View of Go5.5vernment Defense and Others4.7 Have you either through any experience you have had or anything you have seen or read developed any bias or prejudice or othe fee5.1lings fo6.3r or agai ns5t the United Department of Justice the Un ited Atto5.9rney5.9?s Office fo the Southern District of New York the FBI or the NYPD Do you have any opinion5.5s about pros4.7ecutors crimin5.5al defen5.5s-.3e atto rneys generally th5.9at might make it difficul for you to be a fair and imp artial juror in this case Do you have any opinion5.6 about the crimin5.6al ju5.5stice system generally or th5.5e federal criminal justice system in part icular that might make it diff icult for you to be a fair and impa5r-.8tial in th6.2is ca5s5.4e Do you have any opinion about people who are wealthy or have luxur ious lifestyles that might make it difficul for you to be a fair and impar tial juror in this case Case Document Filed Page of Experience as a Witnes4.5s De fendant or Crime Victim For jurors who answered YES to question On your questionnaire you said that you or a fr3.8iend/f3.8a-.4mily member par3.8tic4.6ipat ed a stat-3.4e case What-8.4 kind of case And was your/their role in that case Is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case For jurors who answered YES to question On your questionnaire you said that you or a friend/family member has/have been a victim of a crime Ple4a-1.1se describe4 the circu5.5m-1.7stances including5.5 the ype of crime when it happene and the outc ome of any law enforcement action Is there anything about th at experience that could affect your ability to be fa4.6ir an5.8d impa4.6r-1.2tial in this Juror?s Background How old are you Please state your current county of residence an5.4d list each county of residence durin5.4g the past ten years How far did you go in school And what did you study If you work what kind of work do you do D7.6e-.8scribe the type of your employer for example a private company government entity non-profit organization etc If re4.7tired5.9 or unemployed describe your last employment How long have you been employed in your current position What work did you previously do Who are the members of your household If the me5mb6.2ers of you household work what kind of work do they do What newspapers or magazines do ou typically read and how often Case Document Filed Page of Do you typically read any webs ites If so do you post commen ts or information on these websites Do you regularly use social media If so what social media do you regularly use Do you regularly watch any televisi on shows If so what shows Do you regularly listen to any radio programs or podcasts If so which What are your hobbies ma jor interests recrea tional pastimes and le isure5.8--.1time act4.7iviti4.7es Have you ever followed a criminal ca se in the media If so what case Are you a member of any clubs or organizations to which you contribut time or money FINAL QUESTION I have tried to dir ect your attention in these questions and th rough the questionnaire you filled outthroughout this process to possible reasons why you mig no6.2t able to as a fair and impartial juror Apart from any pr ior question do you have the slightest doubt in your mind for any reaso5.2n.2 whatsoever that you ill able to serve cons4.9cientious4.9ly fairly,5.7 and impar4.1tially in th6.1is case and render a true and just verdic without fear favor sympathy prejud5.7ice and accord5.7ing to the law as it will be explained5.4?-.7 Case Document Filed Page of UNI-4 AT-1 DI-4 RI-4 CT-1 URT OUT-6 HE-1 DI-4 RI-4 OF-1 NE-1 YOR-5 CR AJ-3 D3 ea4 Juror4.6 Y3 ou ct1 re4 t1 urn for t1 xt1 pha3.9 of ury se4 c4 t1 i1 re4 qui1 re4 t1 t1 urn on ay ove0.7 at a.m you t1 Case Document Filed Page of A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 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