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Manafort Jury Questionnaire - June 21, 2018

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Posted on June 21 2018

Seriously take your pick of Manafort entries, here



Fair & unbiased Trial

A Constitutional Right

As prescribed by the Sixth Amendment, a defendant [yes our Constitution is riddled with grammatical and spelling errors]

“In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defence”


Jury Questionare 

Special Counsel Mueller’s  20 page Questionare  open source link found here

The accompanying 8 page filing does NOT have an open source link, should you be inclined to log into PACER:

Case 1:18-cr-00083-TSE

Document 87 Filed


Page 1 of 8

PageID# 1575

...purpose of these questions is to determine whether prospective jurors can impartially decide this case based solely on the evidence presented at trial and the instructions on the law given by the presiding judge.


Also most excellent NEWS. Since I live in the EDVA and would be considered part of the General (federal) Jury pool. I’m absolutely ineligible 😂 not to quibble but my WestLaw search returned >7K entries 


Both the Special Counsel’s investigation and this case in particular have received significant public attention. Potential jurors may have biases or pre-formed opinions as a result of exposure of the widespread media attention. In light of these circumstances, the government submits that a jury questionnaire in addition to standard voir dire procedures will assist the Court in assuring that this case is tried before an impartial jury.

...”Similarly, the same search of transcripts of television and radio broadcasts returned over 1,300 hits, including in major news outlets, such as all major television networks and newspapers, but exclusive of social media like Twitter feeds,”


No really I would absolutely NOT make the cut nor would Mr...who oddly was “selected” to serve as a juror in EDVA for another case but he was later found ineligible.


Special Counsel Mueller’s questionnaire continues:

‘Some of the media accounts question the legitimacy of the Special Counsel’s investigation, tending to advance the opinion that the investigation is ‘tainted’ and therefore its results are suspect,”

“Other media accounts, by contrast, include disparaging descriptions of the defendant. Adverse pretrial publicity can be a significant source of potential prejudice.”


Personally I think it is prudent that these statements are part of the Jury Questionare because it cuts off Manafort’s argument that he could not receive a fair trial. Particularly true, in light of Manafort’s numerous motions to: suppress, limit and exclude evidence. I know I’ve been vocal about Trump’s twitter rants, specifically his unhinged & baseless attacks on Special Counsel Mueller’s Team of Investigators. But that concern is all but confirmed in SC Mueller’s 20 page Questionare.


“Written questionnaires assist both the parties and the court and have important advantages over oral voir dire alone both in exposing bias and in serving the interest of judicial efficiency and economy,” 


Because one of the bedrock principles of our Judicial System is Defendants have a presumption of innocence and it’s completely appropriate for SC Mueller’s Team TL take the bull by the horns and face the potential of a “tainted” jury pool head on, as in BEFORE Manafort’s Trial begins. Otherwise it is reasonable that Manafort would seek a mistrial, specifically that the Prosecution failed (which they haven’t) to exclude any juror who was biased.

This Questionare solves that quagmire that Manafort would potentially use as a legal argument. And it emphasizes that Special Counsel Mueller and his team are nothing but consummate professionals who take their “oath” as an officer of the Court with all due seriousness.

In addition those who know Judge Ellis also know he regularly requires written (specialized) questionnaires coupled with  “supplement oral voir dire, particularly in high profile cases.” Which means Special Counsel Mueller’s Team is listening to the EDVA AUSA. One thing Judge Ellis detest and typically voices his frustration, prosecutors who lack a fulsome understanding of how he runs his Courtroom.


 United States respectfully submits that use of this questionnaire in addition to oral voir dire will assist both the Court and the parties in selecting an impartial jury in this case. The proposed questionnaire also includes background questions to assist in streamlining voir dire and is targeted to probe the critical issues in this case.

The government provided the proposed jury
questionnaire to defense counsel and solicited input but did not receive a response.


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