Free Proposed Voir Dire - District Court of Delaware - Delaware

` Case :06-cr-00124-GIVIS Document 28 Filed 01/15/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE I Q
UNITED STATES OF AMERICA, )
‘ _ E Plaintiff g E
· · v. g Criminal Action No. 06-124—GMS A
LISA REED, g _ ‘
l Defendant. g y L
I GOVERNMENT’S REQUEST FOR SPECIAL VOIR DIRE I
_ NOW COMES the United States of America, by and through its undersigned attorneys, and
hereby requests that the Court submit the following questions to the jury panel in the above-
captioned case. , i
l. Does the length of this trial or the schedule contemplated by the coLn·t present a special
_ problem to any member of the panel?
2. Has any member of the panel heard or read anything about this case? l
I _3. Has any member of the panel or your immediate family (defined as your spouse, child,
I parent or sibling) or close fiiend had any business, social orpersonal dealings with either
_ counsel individually or with the United States Attorney’s Office or the law flnn of
l _ ` Martucci & Peters, LLC?
U ‘ · 4. Has any member ofthe panel or your irnniediate family or close friend had any business,
n _ social or personal dealings with the defendant, Lisa Reed, or with Glenny Coleman, HI? 1

_ Case 1 :06-cr-00124-GIVIS Document 28 Filed 01/15/2008 Page 2 of 3 E
l _ 5. l Members ofthe panel, I am now going to read the names of witnesses who may be called l
. in this case [witness lists to be provided]. Does any member of the panel know any of l
_ B . if ` these persons? i` l
6. Has any member of the panel ever served as a juror in a criminal or a civil case or as a
l member of a grand jury in either a federal or state court? U
7. Has any member ofthe panel ever been involved, in any court, in a criminal matter, other -
· than aminor traffic offense, that concerned yourself a member of your immediate family D U
U or a close friend, either as the subject of an investigation, a defendant, a witness, or a .
l l victim? _ _
. 8. g Has any member ofthe panel, a member of your immediate family, or a close friend had
any dealings — including being employed by, investigated by, or having any other l
· ‘ . association with — the United States Secret Service, the Delaware State Police or any
other law enforcement agency?
U 9. Would the fact that the United States Secret Service and the Delaware State Police are
. the primary investigating agencies in this case interfere with your ability to be fair and i
_ I impartial?
8 an 10. The facts of this case involve applications for loans that were sent to the following _ i
A · entities: Univest National Bank & Trust Company, GMAC Financial Services, p
l i Beneficial Corporation, CitiFina;ncial, Inc., and Aggressive Mortgage. Have any
_ members of the panel had any experiences with these entities, or had any other type of _ pi-
_ loan application experience, that would interfere with your ability to be fair and l
` _ l impartial? l _ .

Case 1 :06-cr-00124-GIVIS Document 28 Filed 01/15/2008 Page 3 of 3
U 1 l. The facts of this case also involve the following car dealerships: Paul Burns Auto Center,
_ Delaware Cadillac, and Murphy Ford, Lincoln-Mercury. Have any members ofthe panel
had any experiences with these entities that would interfere with your ability to be fair
and impartial?
_ l2. If you are selected to sit on- this case, will you be able to render a verdict solely on the
evidence presented at trial and in the context of the law as I will give it to you in my A
instructions, disregarding any other ideas, notions, or beliefs about the law you may have
‘ l or that you may have encountered in reaching your verdict? _ p .
U l3. Is there any member of the panel who has any special disability or problem that would
make sewing as a member of the jury difficult or impossible?
_ 14. 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 juiy and render a fair verdict based on the U
_ evidence presented to you and in the context of the court’s instructions to you on the _
law? l
_ g COLM F. CONNOLLY
U United States Attorney .
J BY: /s/ Christo her J. Burke J
Christopher J. Burke .
- Lesley F. Wolf _
Assistant United States Attorneys _
Dated: January 15, 2008 _ . I I
3 A I ‘ -_