EFTA00085001Set 9
2021-11-2936p7,030w
open court)
(Voir dire resumed)
THE COURT: I have an update. So the one juror on the
4 fifth floor, who's not here, we've not been able ... reach and
5 left a message. The two jurors in 110, here, are not here.
6 One we've not been able to reach and left a message ... propose, counsel, that we take the next available
9 juror in on the first floor.
10 : That's fine with the government, your
11 Honor.
12 MR. EVERDELL: That
https://www.justice.gov/epstein/files/DataSet%209/EFTA00085001.pdf
EFTA00032823Set 8
2021-10-2031p5,264w
DRAFT — October 20, 2021 Juror ID:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
UNITED STATES OF AMERICA
-v- 20 Cr. 330 (MN)
GHISLAINE MAXWELL, JURY
QUESTIONNAIRE
Defendant ... INSTRUCTION SHEET
Dear Juror:
Please call (212) 805 0158 on November 15, 2021 after 6:00 p.m. for further reporting
instructions. Please bring this instruction sheet with ... courthouse if you are
instructed to return.
-I-
EFTA00032823
Juror ID:
JINSERT JUROR INFORMATION SHEET FROM JURY DEPARTMENTS
-2-
EFTA00032824
Juror ID:
PRELIMINARY INSTRUCTIONS
Please read the following instructions carefully
https://www.justice.gov/epstein/files/DataSet%208/EFTA00032823.pdf
EFTA00806757Set 9
2018-11-2656p13,446w
Introduction
5 202.2 Explanation of the Trial Procedure
6 202.3 Note-Taking by Jurors
7 202.4 Juror Questions
8 301.1 Deposition Testimony, Interrogatories,
Stipulated Testimony, Stipulations and
Admissions ... Edwards against
Epstein.
In this case which you have been selected to serve as jurors, Mr. Edwards contends that
Jeffrey Epstein filed knowingly false allegations against Bradley Edwards, that ... claims
brought by Bradley Edwardsfor a total of$5.5 million.
You• job as jurors will be to decide whether Jeffrey Epstein sued Bradley Edwards
maliciously, and, if so whether
https://www.justice.gov/epstein/files/DataSet%209/EFTA00806757.pdf
EFTA00018373Set 8
2021-11-037p1,819w
Ghislaine Maxwell renew our request that the Court release the names of
potential jurors,for attorneys' eyes only, as soon as the written questionnaires are distributed.
Based on the Court ... statement during the October 21 teleconference, it was counsel's
understanding that juror names would be provided to counsel on the Juror Sheet to be inserted in
the questionnaire ... Court's order regarding approval of the video to be played
to prospective jurors, the government importuned the Court to deny counsel the opportunity to
properly vet jurors at this
https://www.justice.gov/epstein/files/DataSet%208/EFTA00018373.pdf
EFTA00084711Set 9
2021-11-037p1,797w
Ghislaine Maxwell renew our request that the Court release the names of
potential jurors,for attorneys' eyes only, as soon as the written questionnaires are distributed.
Based on the Court ... statement during the October 21 teleconference, it was counsel's
understanding that juror names would be provided to counsel on the Juror Sheet to be inserted in
the questionnaire ... Court's order regarding approval of the video to be played
to prospective jurors, the government importuned the Court to deny counsel the opportunity to
properly vet jurors at this
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084711.pdf
EFTA00070837Set 9
2021-03-1241p13,013w
Schmechel, T. O'Toole, C. Easterly, & E. Loftus, Beyond the Ken? Testing Jurors'
Understanding of Eyewitness Reliability Evidence, 46 Jurimetrics J. 177-214 (2006) 34
Ruin
Fed R. Evid ... Many of those opinions are also unreliable, squarely within the ken of
the average juror, or would invade the province of the Court and the jury if offered ... convey any relevant information
11
EFTA00070851
beyond the ken of the average juror and are not helpful to the jury. Instead, they are a virtually
unprecedented attempt to psychoanalyze
https://www.justice.gov/epstein/files/DataSet%209/EFTA00070837.pdf
EFTA00106017Set 9
2020-07-0213p2,790w
indictment
was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively
from the White Plains Division. At no point, however, has the government alleged that ... place into operation a written plan for random selection of grand and petit jurors."
28 U.S.C. § 1863(a). This District's current plan was adopted in 2009. See Amended Plan ... Random Selection of Grand and Petit Jurors in the United States District Court for the
2
EFTA00106021
Southern District of New York ("Jury Plan"), available at
https://nysd.uscourts.govisites/defaultffiles/pdffiuryplan
https://www.justice.gov/epstein/files/DataSet%209/EFTA00106017.pdf
EFTA00099510Set 9
2020-07-0213p2,788w
indictment
was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively
from the White Plains Division. At no point, however, has the government alleged that ... place into operation a written plan for random selection of grand and petit jurors."
28 U.S.C. § 1863(a). This District's current plan was adopted in 2009. See Amended Plan ... Random Selection of Grand and Petit Jurors in the United States District Court for the
2
EFTA00099514
Southern District of New York ("Jury Plan"), available at
https://nysd.uscourts.govisites/defaultffiles/pdffiuryplan
https://www.justice.gov/epstein/files/DataSet%209/EFTA00099510.pdf
EFTA00077249Set 9
2020-07-0213p2,794w
indictment
was obtained using a grand jury seated in White Plains, apparently with jurors drawn exclusively
from the White Plains Division. At no point, however, has the government alleged that ... place into operation a written plan for random selection of grand and petit jurors."
28 U.S.C. § 1863(a). This District's current plan was adopted in 2009. See Amended Plan ... Random Selection of Grand and Petit Jurors in the United States District Court for the
2
EFTA00077253
Southern District of New York ("Jury Plan"), available at
https://nysd.uscourts.govisites/defaultffiles/pdffiuryplan
https://www.justice.gov/epstein/files/DataSet%209/EFTA00077249.pdf
EFTA00009632Set 7
2007-02-0622p4,394w
anyone like to look at
18 any of the documentation today?
19 A GRAND JUROR: what does the documentation
20 constitute, basically, the subpoenas?
21 THE WITNESS: It is primarily ... with the rental cars, and flower shop, you know.
2 A GRAND JUROR: will we have an opportunity
3 later to go through these if we need ... bring them when
S we present the indictment. Yes, ma'am.
6 A GRAND JUROR: If I should hold this for
7 later let me know, she mentioned the hospital
https://www.justice.gov/epstein/files/DataSet%207/EFTA00009632.pdf
EFTA00223910Set 9
2007-02-0622p4,552w
anyone like to look at
18 any of the documentation today?
19 A GRAND JUROR: what does the documentation
20 constitute, basically, the subpoenas?
21 THE WITNESS: It is primarily ... with the rental cars, and flower shop, you know.
2 A GRAND JUROR: will we have an opportunity
3 later to go through these if we need ... bring them when
5 we present the indictment. Yes, ma'am.
6 A GRAND JUROR: If i should hold this for
7 later let me know, she mentioned the hospital
https://www.justice.gov/epstein/files/DataSet%209/EFTA00223910.pdf
EFTA00804787Set 9
2017-11-0946p7,314w
Jeffrey Epstein
3
EFTA00804789
PLAINTIFF/COUNTER-DEFENDANT'S PROPOSED JURY INSTRUCTION NO. 1
101.1 Oath of Jurors Before Voir Dire
Do you solemnly swear or affirm that you will answer truthfully ... questions asked of you
as prospective jurors [so help you God]?
Source:
Florida Standard Jury Instruction (Civil) 101.1
Given
Given as Modified
Denied
Withdrawn
1
EFTA00804790
PLAINTIFF/COUNTER-DEFENDANT'S PROPOSED JURY ... smartphones, tablets, and laptops.
Even though you have not yet been selected as a juror, there are some strict rules that you must
follow about electronic devices.
When
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804787.pdf
EFTA00088057Set 9
2020-03-0521p7,513w
there
are more questions now than when this trial first began," Shroff said to jurors.
Schulte faces several charges, including illegally gathering national defense information, illegal transmission of both
lawfully ... retaliation and lies."
9
EFTA00088065
SDNY News Clips, Thursday, March 5, 2020
WikiLeaks Trial Juror Booted For Looking Up Lawyer Online
Law360
By Pete Brush
3/5/2020
Law360, New York (March ... Manhattan federal judge cut loose a juror from deliberations
Thursday in the trial of Joshua Schulte, the former CIA coder accused of sending secrets to WikiLeaks, because she told
fellow
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088057.pdf
EFTA00088078Set 9
2020-03-0617p7,413w
there
are more questions now than when this trial first began," Shroff said to jurors.
Schulte faces several charges, including illegally gathering national defense information, illegal transmission of both
lawfully ... from prison, repeating that same pattern of
anger, escalation, retaliation and lies."
Wikileaks Trial Juror Booted For Looking Up Lawyer Online
Law360
By Pete Brush
3/5/2020
EFTA00088085
Law360, New York ... March 5, 2020, 5:27 PM EST) -- A Manhattan federal judge cut loose a juror from deliberations
Thursday in the trial of Joshua Schulte, the former CIA coder accused
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088078.pdf
EFTA00088041Set 9
2020-03-0616p7,399w
there
are more questions now than when this trial first began," Shroff said to jurors.
Schulte faces several charges, including illegally gathering national defense information, illegal transmission of both
lawfully ... from prison, repeating that same pattern of anger,
escalation, retaliation and lies."
WikiLeaks Trial Juror Booted For Looking Up Lawyer Online
Law360
By Pete Brush
3/5/2020
Law360, New York (March ... Manhattan federal judge cut loose a juror from deliberations
Thursday in the trial of Joshua Schulte, the former CIA coder accused of sending secrets to WikiLeaks, because she told
fellow
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088041.pdf
EFTA00089986Set 9
2021-11-1023p6,348w
this testimony must be paired with a proper limiting instruction to guard
against potential juror confusion. The Defense has submitted proposed limiting instructions, and
the Government agrees that some sort ... about jury selections. To repeat the basic
17 process, I will qualify 33 potential jurors that represents 12
18 jurors and three alternates, 10 peremptories as to the main ... that point. I will make my preliminary
9 remarks, the written questionnaire that the jurors can read
10 along with will be handed out at that point, both
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089986.pdf