Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1 :07-cr-00137-JJF Document 24 Filed 05/O9/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff,
v. Criminal Action No. 07- I 3 7-J J F
JEFFREY GRAY,
a/k/a “Dahmer," :
Defendant.
GOVERNMENT’S REQUEST FOR SPECIAL VOIR DIRE
The Government, through undersigned counsel, hereby respectfully moves the Court to utilize
the following questions when conducting voir dire in the above- captioned case:
l. Has any member of the panel or your immediate family (defined as your spouse, child,
parent or sibling) or close friend had any business, social or personal dealings with either
counsel — Ilana Eisenstein, Esquire, Keith Rosen, Esquire, or Joseph Gabay, Esquire —
or with the United States Attorney’s Office or the Law Offices of Joseph A. Gabay?
2. Has any member of the panel or your immediate family or close friend had any business,
social or personal dealings with the defendant, Jeffrey Gray?
3. Members ofthe panel, I am now going to read the names of witnesses who may be called
in this case [witness lists to be provided]. Does any member of the panel know any of
these persons?
4. Has any member of the panel ever served as a juror in a criminal or a civil case or as a
member of a grand jury in either a federal or state court?

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5. Has any member ofthe panel ever been involved, in any court, in a criminal matter, other
than a minor traffic offense, that concerned yourself a member of your immediate family
or a close friend, either as the subject of an investigation, a defendant, a witness, or a
victim?
6. Has any member ofthe panel, a member of your immediate family, or a close iiiend had
any dealings with — including being employed by, investigated by, or having any other
association with — a law enforcement agency?
7. Would the fact that the Drug Enforcement Administration, the Bureau of Alcohol,
Tobacco, Firearms and Explosives, and the Federal Bureau of Investigation are the
primary investigating agencies in this case interfere with your ability to be fair and
impartial?
8. This cases involves allegations regarding the possession of a firearm. Has any member
of the panel had any experiences with firearms or does any member of the panel have
views about firearms that would interfere with your ability to be fair and impartial?
9. This case involves various narcotics charges, including charges involving the distribution
of cocaine. ls there anything about the nature ofthe charges that would prevent you from
being an impartial juror?
l0. Have you or any members of your family or friends been charged with a drug crime?
ll. Do you believe that the use or sale of cocaine should be legalized?
l2. Is there any member of the panel who has any special disability or problem that would
make serving as a member of the jury difficult or impossible?
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Case 1 :07-cr-00137-JJF Document 24 Filed 05/O9/2008 Page 3 of 3
13. Having heard the questions put to you by the Court, does any other reason suggest itself
to you as to why you could not sit on this jury and render a fair and impartial verdict
based on the evidence presented to you and based on the CO11I`lC,'S legal instructions?
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY; H Q »-;-
a Eisenstein
Assistant United States Attorney
Dated: Wleés QI goo 3/
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