Appendix V Proposed Questionnaires Submitted by the United States Attorney's Office and the Federal Public Defender's Office in United States V. Zacarias Moussaoui
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UNITED STATES OF AMERICA
v.
ZACARIAS MOUSSAOUI, a/k/a "Shaqil," a/k/a "Abu Khalid al Sahrawi," Defendant
Criminal No. 01-455-A
Hon. Leonie M. Brinkema
The United States respectfully submits the attached proposed jury questionnaire for use in this case.
Respectfully submitted,
PAUL J. McNULTY
UNITED STATES ATTORNEY
By: __________
Robert A. Spencer
David J. Novak
David Raskin
Assistant United States Attorneys
Date: November 28, 2005
I certify that on the 28th day of November, 2005, copies of the foregoing Government pleading were served, by facsimile and regular mail, on the following counsel:
Kenneth R. Troccoli, Esquire
Gerald T. Zerkin, Esquire
Office of the Federal Public Defender
Eastern District of Virginia
1650 King Street
Suite 500
Alexandria, Virginia 22314
Edward B. MacMahon, Jr., Esquire
107 East Washington Street
P.O. Box 903
Middleburg, Virginia 20118
Alan H. Yamamoto, Esquire
643 S. Washington Street
Alexandria, Virginia 22314
/s/_________
David J. Novak
Assistant United States Attorney
This questionnaire is designed to obtain information about your background as it relates to your possible service as a juror in this case. Its use may avoid the necessity of asking these questions of each prospective juror in open court, thereby substantially shortening the jury selection process. The purpose of these questions is to determine whether prospective jurors can impartially decide this case based upon the evidence presented at trial and the instructions on the law given by the presiding judge. The questions are not intended to inquire unnecessarily into personal matters. All information contained in this questionnaire will be kept confidential and under seal.
Respond to each question as fully and completely as possible. Your complete candor and honesty is necessary so that both the prosecution and the defense will have a meaningful opportunity to select an impartial jury. Your cooperation is of vital importance.
You are sworn to give true and complete answers and those answers will be available only to the Court and the parties in this case. The questionnaires belong to the Court and all copies will be returned to the Court once a juror is excused. You are instructed not to discuss this case or the questionnaire with anyone, including your family and fellow jurors.
If you require additional space for your responses, or wish to make further comments regarding any of your answers, please use the Explanation Sheet (page 30). Put the number of the question you are answering on the Explanation Sheet before you write the response or comment.
Please keep in mind that there are no "right" or "wrong" answers, only complete and incomplete answers. Complete answers are far more helpful than incomplete answers.
Unless the question states otherwise, the fact that a particular question is asked does not imply that the subject matter of the question is an issue in this case. As you read the questions, you are not to draw any inferences about the issues that must be decided in this case.
Please fill out the entire questionnaire. Do not leave any questions blank. If a question does not apply to you in any way, write "N/A" rather than leaving the form blank.
Juror Number __________
1. Name: __________
2. Sex: __________
3. Date and place of birth: __________
4. Town or community where you reside: __________
5. Length of time at current address: __________
6. How long have you lived in Northern Virginia? __________
7. If you have lived less than one year at your current address, indicate your prior town or community. __________
8. Please indicate your marital status:
__________ Single and never married
__________ Currently married and have been for ___ years
__________ Single, but married in the past for ___ years
___ Widowed for the past ___ years
9. If you have children or stepchildren, please list them:
Sex Age Live with you? Education Level Occupation
1) __________
2) __________
3) __________
4) __________
10. Are you: (Check any and all that apply)
Self-employed? ___
Employed full-time? ___
Working part-time? ___
Working in the home? ___
Unemployed/laid off? ___
Retired? ___
Student? ___
Disabled and unable to work? ___
11. (a) If employed, what is your current occupation/job title?
__________
(b) What is the name of your employer __________
(c) How long have you held this job? __________
(d) Do you currently have a second job? Yes ___ No ___
If yes, what do you do? __________
If yes, who is your employer? __________
If yes, how long have you held this job? __________
12. Please list all prior occupations during the past ten years.
Occupation Length of Employment
__________ __________
13. If unemployed, please describe other responsibilities that you have (e.g. childcare, school): __________
14. Is your spouse employed? Yes ___ No ___
15. (a) If employed, what is your spouse's current occupation/job title and name of employer? __________
(b) How long has your spouse held this job? __________
16. Check the highest level of education for you and your spouse:
You Spouse
a. Grade school or less __________
b. Some high school __________
c. High school graduate __________
d. Technical or business school __________
e. Some college __________
f. College degree __________
g. Graduate degree (and describe area) __________
If you attended college or received a graduate degree, identify all colleges and graduate schools that you attended __________
17. Do you have any difficulty reading, writing, speaking, or understanding English?
Yes ___ No ___
18. Do you have any problem with your hearing or vision that would make it difficult for you to serve as a juror?
Yes ___ No ___
If yes, please explain __________
19. (a) Do you have any medical condition that would make it difficult for you to serve as a juror for this case? Yes ___ No ___
If yes, please explain __________
(b) Would serving as a juror cause you hardship, economically or otherwise?
Yes ___ No ___
___ If yes, please explain __________
20. Are you taking any prescription medication that may interfere with your ability to concentrate or serve as a juror in any way? Yes ___ No ___
If yes, please explain __________
21. Have you ever been treated for a substance abuse problem (for example, alcohol, illegal or prescription drugs)? Yes ___ No ___
If yes, please explain __________
22. Have you or your spouse ever served in the armed forces? Yes ___ No ___
If yes, please answer the following both as to yourself and/or your spouse:
You Spouse
(a) Branch and highest rank __________
(b) Dates of service __________
(c) Place of Service __________
(d) Type of Discharge __________
(e) Did you or your spouse serve on a court martial, in the military police, shore patrol or other area of law enforcement? Yes ___ No ___
(f) Did you or your spouse ever serve at the Pentagon? Yes ___ No ___
(g) Provide dates of service at the Pentagon, if applicable:
You: __________
Your Spouse: __________
23. (a) Do you have any family, relatives or close friends in the military who are currently or were formerly stationed in the Middle East?
Yes ___ No ___
(b) If yes, where is, or was that person stationed? __________
24. If you, a family member, or close friend served in the military, were you/they ever in a combat situation?
Yes ___ No ___ Don't Know ___
If yes, please tell us where and when: __________
25. (a) Have you ever worked as a firefighter, including as a volunteer, or as a member of a rescue squad or ambulance crew for any federal, state, or local agency?
Yes ___ No ___
(b) If yes, describe the nature of your service? __________
(c) If yes, during what time period(s)? __________
26. (a) Have you ever worked as a commercial pilot? __________
(b) If yes, during what time period and for what airline? __________
27. (a) Have you ever taken any training to become a pilot? Yes ___ No ___
(b) If yes, please describe the training that you had, the time period when you took the training, and identify the school where you took the training: __________
28. (a) Have either you or your spouse worked in an airport?
Yes ___ No ___
(b) If yes, was it you or your spouse? __________
(c) If yes, please provide the time period when you or your spouse worked at the airport and describe the nature of the work: __________
29. How often do you fly on airplanes? (Check the most appropriate answer)
Never ___ Seldom ___ Often ___
30. (a) Have you ever traveled to the Middle East? __________
(b) If yes, please identify the countries where you visited, the time period when your visit occurred, and the reason for your travel: __________
31. (a) Do you know anyone who presently resides in the Middle East?
Yes ___ No ___
(b) If yes, who (the relationship to you) and where? __________
32. (a) Do you speak Arabic (or any dialect of Arabic) or did you grow up in households where the Arabic language or any of its dialects were spoken?
Yes ___ No ___
(b) Do you read any Arabic language newspapers or publications?
Yes ___ No ___
(c) If yes, please list the Arabic language newspapers or publications: __________
(d) If you speak, read or understand the Arabic language (or any or its dialects), would you have any difficulty relying solely upon the official interpreter's translation of testimony, and witnesses' translations of Arabic language evidence?
Yes ___ No ___
33. What newspapers do you read regularly? __________
34. How often do you read a newspaper? __________
35. What magazines do you read regularly? __________
36. (a) Do you listen to news on the radio or watch the news on TV? Yes ___ No ___
(b)...
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