DOJ-OGR-00005331.jpg

545 KB

Extraction Summary

3
People
2
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Court filing (juror questionnaire draft with annotations)
File Size: 545 KB

People (3)

Name Role Context
Defendant Legal Party
Proposed questions regarding holiday plans and COVID-19; responded to government objections. (Implied to be Ghislaine...
Government Legal Party
Objected to specific questions in the questionnaire; took no position on COVID-19 questions.
Juror Subject
The potential respondent to the questionnaire.

Organizations (2)

Name Type Context
Court
Recipient of the joint letter regarding trial length.
Department of Justice (DOJ)
Source of the document release (Bates stamp DOJ-OGR).

Timeline (2 events)

2021-11-29 to 2022-01-15
Trial Window
Courtroom
Jurors Court
2021-12-24 to 2022-01-03
Holiday Period
N/A
Jurors

Locations (1)

Location Context
Mentioned in context of COVID-19 precautions (air filters, larger courtroom).

Relationships (1)

Government Adversarial/Legal Defendant
Exchange of objections and responses in the document comments regarding the phrasing of juror questions.

Key Quotes (3)

"GOVERNMENT OBJECTION: The Government objects to this question on the grounds that the question is duplicative of questions 6 and 7."
Source
DOJ-OGR-00005331.jpg
Quote #1
"DEFENDANT RESPONSE: There are a number of 'plans' for the holidays that do not involve either travel or appointments, about which certain jurors may have strong opinions about missing."
Source
DOJ-OGR-00005331.jpg
Quote #2
"The defendant proposes the questions relating to COVID-19. The Government takes no position."
Source
DOJ-OGR-00005331.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,338 characters)

Case 1:20-cr-00330-PAE Document 367 Filed 10/22/21 Page 9 of 35
Juror ID: _______
6. Do you have any pre-paid travel plans between November 29, 2021 and January 15, 2022?
[ ] Yes [ ] No
If yes, please describe your plans and the dates of travel (without indicating the name of where you work or the names of any family members or friends, or other personal information that might identify who you are):
______________________________________________________________________________
Do you have any holiday plans for the period December 24th through January 3rd?
[ ] Yes [ ] No
7. Do you have any appointments during the next [ ] weeks that cannot be changed?
[ ] Yes [ ] No
If yes, please explain:
______________________________________________________________________________
Have you received a vaccine for COVID-19?
[ ] Yes [ ] No
If Yes, when did you receive the vaccine? ____________________
In light of the COVID-19 pandemic, do you have concerns about your ability to concentrate at trial, consider all the evidence, and make a conscientious decision in deliberation?
[ ] Yes [ ] No
If yes, would courtroom precautions (ex. the use of air filters, use of a larger courtroom) alleviate your concerns?
[ ] Yes [ ] No
Is there any reason relating to the COVID-19 pandemic that would make jury service an undue hardship for you or anyone in your household? [ ] Yes [ ] No
If yes, please explain. _______________________________________________________
Is there anything else going on in your life or work that would prevent you from giving this case your full attention for the duration of trial? [ ] Yes [ ] No
If yes, please explain. _______________________________________________________
-9-
[Comment Boxes]
Commented [A9]: GOVERNMENT OBJECTION: The Government objects to this question on the grounds that the question is duplicative of questions 6 and 7.
Commented [A10R9]: DEFENDANT RESPONSE: There are a number of "plans" for the holidays that do not involve either travel or appointments, about which certain jurors may have strong opinions about missing.
Commented [A11]: The parties will submit a joint letter to the Court on October 12, 2021 providing an estimate of the trial length.
Commented [A12]: The defendant proposes the questions relating to COVID-19. The Government takes no position.
DOJ-OGR-00005331

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