juror number: - justice

JUROR NUMBER: ________

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UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

Hon. Susan D. Wigenton, U.S.D.J. Crim. No. 15-193 (SDW)

JURY QUESTIONNAIRE


Introduction

The purpose of this questionnaire is to assist the Judge, the attorneys, and the parties in selecting a fair and impartial jury for this case. Your full cooperation is of vital importance and will substantially shorten the jury selection process.

This questionnaire is not a test of your knowledge of the laws of the United States. The

rules of law that apply to this case will be explained by the Judge to those persons who actually are selected as trial jurors.

Please read all questions carefully and answer the questions as honestly and completely as

possible. The answers you give must be truthful. At the end of the questionnaire, you will be directed to confirm that your answers are the same as though you were placed under oath. There are no “right” or “wrong” answers, only open and honest ones. As a juror, you will take an oath to be truthful and should approach this questionnaire with that obligation in mind. In order for this process to work, it is important that you are completely candid regarding your actual views and opinions. Everyone involved in this process is relying on what you say. We are genuinely interested in what you think. It will not help if you give answers that are politically correct or that reflect what you think we want to hear or what a “good” juror would say.

This questionnaire will be used only by the Judge and the attorneys for informational

purposes during jury selection. Your answers will not be disclosed to anyone other than the Court, the attorneys representing the parties in this case, and the defendants. If you are not selected as a juror, your questionnaire will be destroyed when jury selection is complete.

UNITED STATES OF AMERICA v. WILLIAM E. BARONI, JR. and BRIDGET ANNE KELLY


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VERIFICATION SHEET

Please note: The Jury staff will detach this page from the questionnaire when you turn it in. No one else will see this page. I swear that the answers given by me to the questions on this Juror Questionnaire are truth, to the same effect as if I were sworn under oath, in open court, to give truthful answers to the same. ________________________ Juror Signature Juror No. _________________ Date: _____________ _______


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Instructions

1. Please write legibly.

2. Print your name and juror number at the top of each page where designated. 3. This questionnaire is double-sided. Please do not leave any question unanswered. If you do not understand a question, or do not know the answer, please write, “I do not understand,” or “I do not know.” If there are things you do not want to talk about in open court, please circle the question numbers and write “PRIVATE” on the front page of the questionnaire. 4. If you require additional space for your responses or wish to make further comments regarding any of your answers, you may do so on the Explanation Sheets at the end of this questionnaire. Please indicate the number of the question to which you are referring on the Explanation Sheets before writing your response or comment. 5. The fact that a particular question is asked does not imply that the subject matter of the question is an issue in the case. As you read the questions, do not draw any inferences about the issues that must be decided in this case.


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UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

Hon. Susan D. Wigenton, U.S.D.J. Crim. No. 15-193 (SDW)

JURY QUESTIONNAIRE


Preliminary Questions

1. The attorneys in this case and I are going to see that it is tried as quickly and as efficiently as we can. It will likely take approximately 6 weeks to try. Is there any extraordinary personal or business situation that makes it impossible for you to sit on this jury? [ ] Yes [ ] No

If YES, please explain.

________________________________________________________________________________________________________________________________________________

2. Do you feel that you have difficulty reading, speaking or understanding English? [ ] Yes [ ] No

3. Do you have any special disability, hardship, or problem, or is there anything that would make it difficult or impossible for you to serve as a member of this jury, or that would need an accommodation by the Court? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

4. Are you now taking or do you anticipate taking any medication that in any way might affect your attention or your ability to concentrate, understand, consider and weigh the evidence in this case? [ ] Yes [ ] No

UNITED STATES OF AMERICA v. WILLIAM E. BARONI, JR. and BRIDGET ANNE KELLY


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If YES, please indicate which type of medication and what type of effect it might have. ________________________________________________________________________________________________________________________________________________

5. The defendants in this case are William E. “Bill” Baroni, Jr. and Bridget Anne Kelly.

(a) Do you personally know the defendants or any members of their families? [ ] Yes [ ] No If YES, who do you personally know? ____________________________________________________________________________________________________________________________________

(b) Have you ever had any interactions with individuals who worked for or with either of the defendants? [ ] Yes [ ] No

If YES, please explain:_______________________________________________ __________________________________________________________________ 6. The government in this case is represented by Lee Cortes, David Feder, and Vikas Khanna

of the United States Attorney’s Office in Newark, New Jersey. Mr. Baroni is represented by Michael Baldassare, Jennifer Mara, Dillon Malar of Baldassare and Mara, LLC, located in Newark, New Jersey. Ms. Kelly is represented by Michael Critchley, Sr., Michael Critchley, Jr., Edmund Denoia, and Christopher L. Fox of Critchley, Kinum & Denoia, LLC, located in Livingston, New Jersey. Do you or any family member or close friend personally know any of them? [ ] Yes [ ] No

If YES, who do you personally know and how? ________________________________________________________________________________________________________________________________________________

7. The judge presiding over this case is U.S. District Judge Susan D. Wigenton. Do you or does any family member or any close friend personally know Judge Wigenton or anyone else who works in this courthouse? [ ] Yes [ ] No

If YES, who do you personally know and how? ________________________________________________________________________________________________________________________________________________


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8. On Attachment A (i.e., the last page of this document) is a list of individuals who may be called to testify in this case or who may be referred to during testimony. (a) Do you personally know any of the people listed on this sheet?

[ ] Yes [ ] No If YES, who do you personally know and how? ____________________________________________________________________________________________________________________________________

(b) Do you have any opinions about anyone on Attachment A, favorable or unfavorable, that might affect your ability to be fair and impartial in this case? [ ] Yes [ ] No If YES, please explain:_______________________________________________ __________________________________________________________________ __________________________________________________________________

Background

9. What town and county do you live in? ________________________________________________________________________________________________________________________________________________

10. How long have you lived at your current address? ________________________________________________________________________________________________________________________________________________

11. Do you rent or own your home? ________________________________________________________________________________________________________________________________________________

12. Where did you grow up? ________________________________________________________________________________________________________________________________________________

13. Are you (check any and all that apply): [ ] Self-employed [ ] Unemployed [ ] Employed full-time [ ] Retired [ ] Working part-time [ ] Homemaker [ ] A student [ ] Disabled and unable to work


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14. If you are currently employed in any capacity, either full-time, or part-time, please state:

(a) Occupation: _____________________________________________________

(b) Employer (Name and City/State): _______________________________________________________

(c) How long have you been working for your current employer? _______________

(d) Type of work: _____________________________________________________

(e) Do you manage or supervise others?

[ ] Yes [ ] No

(f) Do you have any responsibility for hiring or firing? [ ] Yes [ ] No

15. If you are not currently employed, please state:

(a) Your last employer & last date worked: _________________________________________________

(b) Your occupation:____________________________________________________ (c) How long did you work for your last employer? _______________

(d) Type of work: _____________________________________________

(e) Did you manage or supervise others?

[ ] Yes [ ] No

(f) Did you have any responsibilities for hiring or firing? [ ] Yes [ ] No

16. What is your current marital status? [ ] Never Married [ ] Divorced [ ] Living with Significant Other [ ] Separated [ ] Married [ ] Widowed

17. If you are married or currently share a household with someone who is employed in any capacity (full-time or part-time), please provide the following information for that individual:

(a) Occupation:________________________________________________________

(b) Employer (Name & City/State): ________________________________________________________


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(c) Type of work:______________________________________________________

18. If you are divorced or if your spouse is deceased, please state the following for that individual:

(a) Occupation:________________________________________________________

(b) Employer:________________________________________________________

(c) Type of work:______________________________________________________

19. If you have children, please state the following:

(a) Age(s):________

(b) Occupation(s) (if employed): ___________________________________________

(c) Employer:________________________________________________________

(d) Type of work:_____________________________________________________

20. Have you or has any family member served in any branch of the Armed Forces? [ ] Yes [ ] No (a) If yes, please list their relationship to you, branch, and highest rank. Relationship Branch Highest rank

________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

21. Do you or does anyone in your household belong to a union? [ ] Yes [ ] No (a) If YES, please identify the union and who belonged to it____________________

_________________________________________________________________

(b) If you previously belonged to a union, which one?________________________


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(c) One or more witnesses in this case may be affiliated with a union or hold leadership positions in a union. Do you have any opinions, feelings, or experiences (positive or negative) which would cause you to believe or disbelieve the testimony of such witnesses more readily than the testimony of any other witness? [ ] Yes [ ] No

If YES, please explain________________________________________________ __________________________________________________________________

22. Have you or has anyone in your household worked or served in an ambulance corps or as an emergency services technician? [ ] Yes [ ] No (a) If YES, who served, where and when?__________________________________

_________________________________________________________________

23. What was the highest educational degree you attained?___________________________

(a) What was the name of the last school attended, and in which city and state was it located?__________________________________________________________

(b) If applicable, what was your major, specialization, or concentration of study? ____________________________________________________________________________________________________________________________________

24. What are your hobbies? ________________________________________________________________________________________________________________________________________________

25. Please list the clubs or organizations to which you or your spouse/partner belong or in which you or your spouse/partner participated, either now or during the last five years.

(a) Self:________________________________________________________________________________________________________________________________

(b) Spouse/Partner:_______________________________________________________________________________________________________________________

26. Please list any television programs you watch for enjoyment (including programs on streaming services like Netflix and Amazon Prime) and indicate for each how often you watch. ________________________________________________________________________________________________________________________________________________________________________________________________________________________


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27. Please list any television news programs you watch and indicate for each how often you watch. ________________________________________________________________________________________________________________________________________________________________________________________________________________________

28. Please list any newspapers (including tabloids) that you read. ________________________________________________________________________________________________________________________________________________________________________________________________________________________

29. Please list any Internet web sites that you visit regularly, or any e-mail lists, blogs, Twitter accounts or message services you subscribe to, for news/current events. ________________________________________________________________________________________________________________________________________________________________________________________________________________________

30. Please list any social media you use (including Facebook, Google+, Twitter, Instagram, Snapchat) and indicate the frequency of use? ________________________________________________________________________________________________________________________________________________________________________________________________________________________

31. Do you have any Google Alerts or a similar service set up for anything or anyone related to this case? [ ] Yes [ ] No

If YES, which one?__________________________________________________

32. Do you receive Tweets or similar updates about this case or anyone related to it? [ ] Yes [ ] No If YES, please describe. __________________________________________________ ________________________________________________________________________

33. Please list any entities or accounts that you “follow” on Twitter that are in any way related to politics, political figures / parties, political reporting, or current events: ________________________________________________________________________________________________________________________________________________


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34. Do you or your spouse/partner maintain or regularly contribute to a blog or online journal? [ ] Yes [ ] No If YES, please describe. __________________________________________________ ________________________________________________________________________

35. Have you ever written, posted comments, or been quoted in any paper, article, newsletter, news media report, book, or other published work, including online, print and other media sources? [ ] Yes [ ] No If YES, please describe the date, content, and the source of publication. _____________ ________________________________________________________________________________________________________________________________________________________________________________________________________________________

36. Have you ever written to any newspaper or magazine; or called in to any television or radio program; or posted a comment or a “like” on any website or to an online media story to express your opinion concerning politics? [ ] Yes [ ] No If YES, please describe the view you expressed and in what manner. ______________ ________________________________________________________________________________________________________________________________________________________________________________________________________________________

37. Please list any podcasts you listen to. ________________________________________________________________________________________________________________________________________________

38. What bumper stickers or magnets have you had on the vehicle you have driven during the past 5 years? ________________________________________________________________________________________________________________________________________________

Media Coverage

39. Have you formed any ideas or opinions about this case based on what you have heard or read about it? [ ] Yes [ ] No


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40. Despite having heard or read about this case, would you be able to decide this case based solely on the evidence presented in the courtroom and the instructions on the law that the Court will provide? [ ] Yes [ ] No

If NO, please explain.______________________________________________________ ________________________________________________________________________

41. Have you spoken to anyone about this case? [ ] Yes [ ] No If YES, please describe the substance of the conversation(s).___________________________________________________________________________________________________________________________________ If YES, can you set aside those conversations and follow the Court’s instructions to decide this case based on the facts presented and the law as the Court instructs you? [ ] Yes [ ] No

42. Is there anything about the nature of this case that would make it difficult or impossible for you to render a fair and impartial verdict or to follow the Court’s instructions on the law? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________

43. This trial will receive media attention. The Court wants to make sure that this case is decided solely on the evidence presented in the courtroom and not based on things that are said outside the courtroom. As a result, the jury will be instructed not to read about the case in the newspapers or on the Internet, listen to any radio or television reports about the case, or do research regarding the case, the parties, the lawyers, or the Judge. You must avoid discussing this case with friends or family. This includes communications, postings, or discussions through e-mail, texting, or social media sites (such as Facebook and Twitter). Will you be able to follow these instructions?

[ ] Yes [ ] No

(a) If NO, please explain. ______________________________________________ ____________________________________________________________________________________________________________________________________


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Jury Experience

44. Have you ever served as a juror before? [ ] Yes [ ] No If YES, indicate for each: Year Civil/Criminal Federal/State Type of Case Verdict ________________________________________________________________________________________________________________________________________________________________________________________________________________________ For any case that reached a verdict, how long did you deliberate?___________________

45. Have you ever served as a juror on a grand jury? [ ] Yes [ ] No (a) If YES, when and where? ____________________________________________

46. Have you ever served as a jury or grand jury foreperson? [ ] Yes [ ] No

47. Would anything about your previous experience as a juror impair your ability to serve as a fair and impartial juror in the trial of this case? [ ] Yes [ ] No

If YES, please explain._____________________________________________________ ________________________________________________________________________

48. Has a family member or close friend served on a trial jury?

49. [ ] Yes [ ] No

(a) If YES, what do you know of that person’s experience in serving on that trial jury? ____________________________________________________________________________________________________________________________________

(b) Would that knowledge in any way impair your ability to serve as a fair and impartial

juror in this case? [ ] Yes [ ] No

If YES, please explain._______________________________________________ ____________________________________________________________________________________________________________________________________


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Contacts with the Legal System

50. Have you or has any family member or any close friend ever been the victim of a crime? [ ] Yes [ ] No If YES, please explain for the following: (a) What was the crime?________________________________________________

(b) When did the crime occur?___________________________________________

(c) Was the crime reported to the police? [ ] Yes [ ] No

(d) If the crime was not reported to the police, why was it not reported?___________

_________________________________________________________________

(e) Were any arrests made? [ ] Yes [ ] No

(f) Did the case go to trial? [ ] Yes [ ] No

(g) Did you, your relative, or your friend testify in the grand jury, at any hearings, or at the trial itself? [ ] Yes [ ] No

(h) Were you or was your relative or your friend satisfied with the work of the police, the attorneys, or the courts? [ ] Yes [ ] No If NO, please explain._______________________________________________ __________________________________________________________________

(i) Was there anything about this experience that would prevent you from being fair and impartial to both sides in deciding this case? [ ] Yes [ ] No

If YES, please explain._______________________________________________ __________________________________________________________________

51. Have you or has any family member or any close friend ever witnessed a crime? [ ] Yes [ ] No If YES, please provide the following information:

(a) What crime was witnessed?___________________________________________

(b) When did the crime occur?____________________________________________

(c) Was the crime reported to the police? [ ] Yes [ ] No


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(d) Were you or was your relative or your friend interviewed by the police? [ ] Yes [ ] No

(e) Did you, your relative, or your friend testify in any proceeding? [ ] Yes [ ] No

(f) Were you or was your relative or your friend satisfied with the work of the police, the attorneys, or the courts? [ ] Yes [ ] No

If NO, please explain:_______________________________________________ __________________________________________________________________

(g) Was there anything about this experience (or your knowledge of this experience) that would prevent you from being fair and impartial to both sides in deciding this case? [ ] Yes [ ] No If YES, please explain._______________________________________________ __________________________________________________________________

52. Have you or has any family member or any close friend ever been accused of any crime?

(a) Who was accused of the crime, and what is your relationship to that person?_____ __________________________________________________________________

(b) What was the accusation? ____________________________________________ __________________________________________________________________

(c) When was the accusation made? _______________________________________ __________________________________________________________________

(d) What happened to the case? ___________________________________________ __________________________________________________________________

(e) Do you believe that the police, the prosecution, and the courts acted fairly in connection with this matter? [ ] Yes [ ] No If NO, please explain._______________________________________________ ____________________________________________________________________________________________________________________________________


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(f) Would this experience cause you to favor the defendant or be biased against the United States in this case? [ ] Yes [ ] No If YES, please explain._______________________________________________ ____________________________________________________________________________________________________________________________________

53. Have you or has any family member or any close friend ever been the subject of an investigation by any agency of the United States, such as the Department of Justice, the Federal Bureau of Investigation (FBI), or an Inspector General’s Office, or by any agency of a state or local government? [ ] Yes [ ] No (a) If YES, who and by which agency?____________________________________

_________________________________________________________________

(b) Would this experience cause you to favor the defendant or be biased against the United States in this case? [ ] Yes [ ] No If YES, please explain._______________________________________________ ____________________________________________________________________________________________________________________________________

54. Have you, or has any family member or any close friend, ever participated in a civil case or an administrative proceeding, including but not limited to bankruptcy proceedings and shareholder derivative actions, as a plaintiff, a defendant, a witness, or in some other capacity? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________

55. Have you or has any family member or any close friend ever had any case, dispute, or claim, whether civil or criminal, against the United States Government or any law enforcement agency? [ ] Yes [ ] No If YES, please explain. ____________________________________________________ ________________________________________________________________________


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(a) Do you reasonably anticipate such a claim arising in the future? [ ] Yes [ ] No


(b) Would this factor prevent you from being fair and impartial to both sides in deciding this case? [ ] Yes [ ] No


56. Have you or has any family member or any close friend ever testified in a criminal case? [ ] Yes [ ] No (a) If YES, please provide the following details:

Type of case Relationship (if any) ________________________________________________________________________________________________________________________________________________________________________________________________________________________

(b) Please describe the subject of the testimony_______________________________ __________________________________________________________________

(c) Was there anything about that experience that would prevent you from being fair and impartial to both sides in deciding this case? [ ] Yes [ ] No If YES, please explain._______________________________________________ __________________________________________________________________

57. Have you, or has any family member or any close friend, ever studied or practiced law? [ ] Yes [ ] No If YES, who?_____________________________________________________________

58. Have you, or has any family member or any close friend, ever worked in a law office? [ ] Yes [ ] No

If YES, who?_____________________________________________________________


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59. Some of the witnesses in this case may be attorneys. Do you have any opinions, feelings, or experiences (positive or negative), which would cause you to believe or disbelieve the testimony of an attorney more readily than the testimony of any other witness? [ ] Yes [ ] No If YES, please explain._____________________________________________________ _______________________________________________________________________

Contacts with Law Enforcement

60. Have you, any family member, or close friends ever worked in law enforcement in any capacity, either for a police or sheriff’s department, a prosecutor’s office (federal, state or local), the Federal Bureau of Investigation (FBI), an Inspector General’s (“IG”) Office, the Port Authority Police Department, or in any other job related to the enforcement or administration of the law? [ ] Yes [ ] No If YES, please indicate for each:

(a) Employer:_________________________________________________________

(b) Job title:__________________________________________________________

(c) Primary duties and responsibilities: _____________________________________

(d) Approximate dates of employment: _____________________________________

(e) Reason for leaving: _________________________________________________

(f) Would anything about your employment or your family member’s or close friend’s employment in law enforcement affect your ability to be fair and impartial both to the defendant and to the United States in deciding this case? [ ] Yes [ ] No If YES, please explain.______________________________________________ _________________________________________________________________


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61. Some of the witnesses in this case may be employed by or affiliated in some way with a law enforcement agency. Do you have such strong views about law enforcement agents, favorable or unfavorable, that you would tend to believe or not believe a law enforcement agent’s testimony just because of his or her position? [ ] Yes [ ] No If YES, please explain._____________________________________________________ _______________________________________________________________________

Contacts with Public Officials

62. Have you or has any family member or any close friend been employed by any public agency or authority, including any municipal, county, state, or federal government? [ ] Yes [ ] No If YES, please provide the following information:

(a) What is your relationship to this person?_________________________________

(b) Identify the employer._______________________________________________

(c) Have you talked to this person about his or her work? [ ] Yes [ ] No

If YES, how often?__________________________________________________

(d) Would your relationship or conversations with this person in any way affect the way that you think about this case? [ ] Yes [ ] No

If YES, please explain.______________________________________________ __________________________________________________________________

63. Have you or has any family member or any close friend ever run for political office in the local, state, or federal government (regardless of success)? [ ] Yes [ ] No If YES, please provide their names, relationship to you and political office: _______________________________________________________________________ ________________________________________________________________________________________________________________________________________________


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64. Have you or has your spouse/partner, any family member, or any close friend ever done any of the following for any candidates for public office, political organizations, political committees, or political action committees (PACs): (Check all that apply)

Self Spouse/ Family/ Partner Close Friend (a) Been paid to work for [ ] [ ] [ ] (b) Volunteer work [ ] [ ] [ ] (c) Canvassed neighborhoods [ ] [ ] [ ] (d) Attended meetings [ ] [ ] [ ] (e) Contributed money [ ] [ ] [ ] (f) Attended rallies [ ] [ ] [ ] (g) Attended fundraising events [ ] [ ] [ ] (h) Displayed yard signs [ ] [ ] [ ]

65. During this trial, you may learn that a witness or defendant is a member of a particular

political party, such as Republican or Democrat.

(a) If you were to learn that a witness or defendant is a member of the Democratic party, would that fact affect your ability to be fair and impartial in this case? [ ] Yes [ ] No

(b) If you were to learn that a witness or defendant is a member of the Republican party, would that affect your ability to be fair and impartial in this case? [ ] Yes [ ] No

66. Here, the defendants are alleged to be former public officials. Would you be willing and able to evaluate the case against them solely based on the evidence in Court and the Court’s instructions on the law, regardless of how you feel about public officials? [ ] Yes [ ] No If NO, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

67. Some of the witnesses in this case will be current or former public officials. Do you have such strong views about public officials, favorable or unfavorable, that you would tend to believe or not believe a public official’s testimony just because of his or her position? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________


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68. Have you or has any family member or any close friend had any experience with a public or government official that could affect the way you feel about public officials or office holders? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

Lawful Searches

69. During the trial you will see evidence (including emails and text messages) that was lawfully seized.

(a) Do you have any negative opinions about searches of emails, phone communications, and other electronic records or about the searches of private premises and the use at trial of records obtained in such searches, even if the searches were entirely legal and proper? [ ] Yes [ ] No


Case Specific Questions

70. Do you have any family member or close friend who lives or has lived in Fort Lee in the last five years? [ ] Yes [ ] No

71. Have you ever lived in Fort Lee? [ ] Yes [ ] No

72. Were you, any family member, or close friend in any way affected by the lane and toll booth reductions in Fort Lee at any time from September 9, 2013 through September 13, 2013? [ ] Yes [ ] No

If YES, please explain who was affected and how:_______________________________ ________________________________________________________________________________________________________________________________________________


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73. Please describe what (if any) business dealings you, a family member, or close friend has had with the following entities:

(a) the Borough of Fort Lee:____________________________________________

(b) the Port Authority of New York and New Jersey (apart from the routine use of Port Authority facilities including Newark Airport, the Hudson River bridges and tunnels, the PATH, etc.):_____________________________________________ _________________________________________________________________

(c) the Office of the Governor of the State of New Jersey: _____________________ _________________________________________________________________

(d) the 2013 Chris Christie for Governor Reelection Campaign (apart from voting in the 2013 N.J. gubernatorial election): ____________________________ _________________________________________________________________

74. Do you commute to work or have you commuted to a previous job? If YES, please describe your method of commuting (by car or public transportation) and your usual route. ________________________________________________________________________________________________________________________________________________

75. Do you or does any family member or close friend use the George Washington Bridge on a regular basis? [ ] Yes [ ] No If YES, please provide the following information:

(a) Frequency of use (e.g., daily, occasionally): ______________________________

(b) Access route to the New York-bound lanes of the George Washington Bridge (Highways 80-95, Palisades Parkway, local streets): _______________________ _________________________________________________________________

76. During the course of this trial, you may hear testimony from people who have agreed to cooperate with the government, entered into plea agreements, pleaded guilty to crimes, and may be sentenced less severely as a result of their cooperation. Some cooperating witnesses may be alleged accomplices with the defendants.

(a) If such cooperating witnesses were to testify, would you be able to fairly and impartially consider and evaluate the cooperating witness’s testimony? [ ] Yes [ ] No

If NO, please explain.________________________________________________ __________________________________________________________________


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(b) Do you have any feelings or opinions that would cause you to say that you would never believe the testimony of a cooperating witness? [ ] Yes [ ] No

If YES, please explain._______________________________________________ _________________________________________________________________

(c) Do you have any negative feelings or opinions about anyone who cooperates with the FBI or any other law enforcement agency? [ ] Yes [ ] No


77. During the trial, you may hear evidence about inquiries from the media. Do you have any strong opinions or views about the media’s reporting on politics or government that could affect your ability to be fair and impartial in this case? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

Concluding Questions

78. If you are selected to sit as a juror in this case, would you be willing and able to render a verdict based solely on the facts, objects, and documents in evidence and the Court’s instructions on the law, disregarding any other ideas, notions, or beliefs about the law that you may have encountered? [ ] Yes [ ] No If NO, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

79. Would you be able to put aside any possible bias or prejudice or sympathy for or against any party that may arise during the trial and decide the case solely upon the evidence and according to the law as explained by the Court? [ ] Yes [ ] No If NO, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________


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80. Would you be influenced by the religion, race, color, sex, sexual orientation or ethnic background of a witness in considering the believability of his or her testimony? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

81. Do you know of any reason why you may be prejudiced for or against the government, for or against any witness, or for or against either defendant because of the nature of the charges or otherwise? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

82. Do you have any opinions, religious beliefs, philosophies, or prejudices that would make it difficult for you to reach a verdict in this (or any) case? [ ] Yes [ ] No If YES, please explain._____________________________________________________ ________________________________________________________________________________________________________________________________________________

83. As a matter of law, the possible punishment for a violation of the criminal law is for the Court solely to decide. Will you have a problem rendering a verdict as to guilt or innocence without regard to any potential punishment? [ ] Yes [ ] No If YES, please explain._____________________________________________________ _______________________________________________________________________________________________________________________________________________

84. The defendants in this case are presumed innocent until proven guilty. An indictment is not evidence of guilt. It is simply a charging document and a defendant in a criminal case is presumed innocent until proven guilty. Would the fact that the defendants have been indicted, and are facing criminal charges, cause you to have preconceived opinions on their guilt or innocence? [ ] Yes [ ] No If YES, please explain._____________________________________________________ _______________________________________________________________________________________________________________________________________________


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85. A defendant in a criminal case has an absolute right to remain silent and has an absolute right not to testify. I will instruct you that if Mr. Baroni or Ms. Kelly chooses not to testify, you are not to consider that in any way in determining his or her guilt or innocence. If Mr. Baroni or Ms. Kelly chooses not to testify, would you draw any negative conclusions from that decision? [ ] Yes [ ] No If YES, please explain._____________________________________________________ _______________________________________________________________________________________________________________________________________________


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ATTACHMENT A

Abraham, Matthew Adams, Robert Agro, Charles Akil, Muhammed Alpert, Jay Altilio, Antonio Alvarez, David Alwell, Robert Amato, Sharon Amodeo, John Angelini-Bianchi, Toni Apfel, Howard Archie, Gwendolyn Ashmore, Jeanne Attanasio, Anthony Bader, Jeffrey Bagger, Rich Bardzilowski, Joseph Barnable, Michael Baroni, William Bartolotta, Christopher Barlas, Al Bates, Jennifer Bell, Matthew Bencivengo, Gina Bencivengo, John Bendul, Keith Benjamin, Matthew Bermudez, Ruben Bertoli, Thomas Blay, Lee Ann Blinker, Darryl Bollwage, Christian Boozang, Kathleen Brodsky, Reed Brook, Rachel Brown, Lynette Brown, Michele

Buchbinder, Darrell Buono, Barbara Buono, Charles Butcher, Ernesto Camus, James Capalbo, Bruna Capuano, Louis Carvagno, Anthony Case, John Celler, Michael Cervieri, Joseph Chiesa, Jeffrey Christie, Christopher Chung, Victor Coleman, Steven Comella, Maria Connolly, Kathy Constable, Richard Cordero, Angelo Coutinho, Al Crifo, Nicole Crist, Paul Cronin, James Cunningham, Sandra Cuomo, Andrew Curley, John Curry, Steven Danielides, Phillippe Dawson, Stephanie DeCerreno, Allison DeFilippis, Michael DePalma, Amanda DeRose, Richard DeShepio, John Diaz, Wilda Dickens, Thomas DiMarco, Damon DiMarco, Gretchen


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DiVincenzo, Joseph Dolan, Sarah Doughney, Christina Drewniak, Michael Drewniak, Nicole Davidman Ducote, Jonathan DuHaime, Michael Dunne, Joseph Durando, Robert Durrant, Arthur Eastman, Karen Egan, Aileen Egbert, Robert Egea, Regina Eslinger, Robert Evans, George Falk, Andi Farfalla, Frank Farrington, Ray Favia, Paul Ferrara, Susan Fiocchi, Samuel Fiorilli, Dominick Fischer, Judith Farrell, Jeremy Ford, Timothy Forrest, June Fox, Jamie Foye, Patrick Frank, Gloria Fulop, Steven Fulton, Cedrick Gaw, Mark Garten, David Gembara, Paul Gilroy, Jim

Glaser, Howard Goetting, Louis Goldberg, Jan Graham, John Graham, Ryan Gramiccioni, Deborah Greco, Robert Guadagno, Kim Hackett, Christopher Harriott, Thomas Harwood, Brett Hauser, Kathy Hayes, Anthony Herrera, Lisa Holden, Ronald Hoyt, Sherry Hwang, Amy Iannacone, Rosemary Jackson, Christopher Jacobs, Daniel Jaslow Schatz, Debbie Jobes, Thomas Joyce, Robert Kahlbaugh, David Kasofsky, Ila Keellen, Thomas Kelaher, Thomas Kelly, Bridget Khem, John Klass, Kelly Ann Koumoutsos, Louis Krautman, Wolfgang Kuhn, Alyssa Kushner, Jared Kwon, Phil Lado, Christina


29

Lavin, William Lax, Jonathan Lee, Connie Lee, Kevin Leodori, Maryanne Leonard, James Lessieu, Jennifer Levesque, Richard Licorish, Darcy Lipper, Kenneth Lopez, Bernie Luna, Frank Lynford, Jeff Ma, John MacSpadden, Lisa Mahoney, Thomas Malloy, Patricia Mancini, James Manfredi, Raymond Martin, Robert Mastro, Randy Matey, Paul McAusland, John McCarron, Daniel McCullough, Sonny McCoy, James McDaniel, Dustin McKenna, Charles McManus, Shannon Meehan, John Mesuda, Stacie Michaels, Jeffrey Michaels, Thomas Michel, Robert Middlebrooks, Julie Miller, Kristina

Mirkovic, Ricky Moallem, Michelle Moerdler, Jeffrey Monfiletto, Sue Monks, William Morris, Robert Mouli, Ashok Mowers, Matthew Mroz, Richard Mullen, William Muriello, Mark Napolitano, Stephen Napolitano, Vincent Nebel, George Nixon, Margarete Nunziata, John Nunziato, Paul O'Dowd, Kevin O'Keefe, Matthew Orscher, Christian O'Scanlon, Declan O'Toole, Kevin Panebianco, Barbara Park, Veronica Palatucci, William Pasichow, Steven Patel, Umang Pickles, Michelle Pilosio, Jared Pisciotta, Steve Pocino, Raymond Pohan, Armand Pollan, Antonio Porrino, Chris Potter, Caroline Pruzansky, Josh


30

Quelch, Gerard Quello, Melissa Ramirez, Enrique Rebisz, Richard Rechler, Scott Reed, Colin Reiner, David Renna, Christina Renna, Michael Rhem, Nadine Riall, Denise Ridley, Evan Riva, Theresa Rivera, Jose Roberts, Kevin Robles, Daniel Rodriquez, Raymond Roque, Felix Rosado, Rossana Rudder, Scott Russo, David Sama, Rajiv Samson, David Sampson, Natalie Sargenti, Michael Sartor, Anthony Saxton, Paul Schatzts, Debbie Schaff, Mark Schepisi, Holly Schroeder, Robert Schuber, William “Pat” Schwartz, Rebecca Schwarz, Arielle Shabih, Raheel Sheridan, Peter

Simpson, James Simon, Brian Sloan, Stewart Smith, Mark Smith, Terri Sohmer, Harvey Sokolich, Mark Sommero, Thomas Southwell, Alexander Spodofora, John Stack, Brian Stark, Christopher Steinberg, Samantha Steiner, David Stepien, William Sundstrom, Kerstin Tagliarini, Fred Tait, Angela Thieroff, John Thomas, Peggy Tintle, Kieran Tobias, Christine Tosney, Michael Tremmell, Ian Valens, Christopher Valentin, Doris Van Wetering, Russell Vicari, Joseph Walters, Suzanne Warlikowski, Nancy Weiss, Sy Weissman, Francine Weitzman, Avi Westervelt, Ron Westrick, Lisa White, RJ


31

Wildstein, David Wong Yang, Debra Wood, Brian Woodbyrne, Deirdre Yostpile, Bernie

Young, Bill Zimmer, Dawn Zipf, Peter Zusi, Daniel

juror number: - justice

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