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Monday, November 13, 2006

Fitzgerald Proposed voir dire [Doc 182]


     Case 1:05-cr-00394-RBW            Document 182         Filed 11/13/2006       Page 1 of 11



                              UNITED STATES DISTRICT COURT
                              NORTHERN DISTRICT OF ILLINOIS
                                    EASTERN DIVISION

UNITED STATES OF AMERICA                       )
                                               )       Cr. No. 05 CR 394 (RBW)
               v.                              )
                                               )
I. LEWIS LIBBY                                 )

                 GOVERNMENT'S PROPOSED VOIR DIRE QUESTIONS

        The government respectfully submits the following voir dire questions for use in the trial of

this case.

Demographic Information

        1.     Hold old are you?

        2.     What is the name of the neighborhood in which you live (for example, Shaw, Adams,

Morgan, Georgetown)? How long have your lived at your present address? Have you have lived

anywhere else in the past ten years and, if so, where, and for how long? Where did you grow up?

Educational Background

        3.     What is the highest level of schooling you have received? If you attended college,

trade or vocational school after high school, where did you attend? What were your major areas of

study, and what degree(s) or certificate(s) did you earn?

Family History

        4.     Are you currently single, married, divorced, separated, or widowed?

        5.     Do you have any children, stepchildren, or grandchildren? Do any of them live with

you? Please briefly tell us as to each child, stepchild, and grandchild, how old they are, their gender,

their current employment or occupation, if any, and whether they live with you.



    Case 1:05-cr-00394-RBW            Document 182         Filed 11/13/2006       Page 2 of 11



Employment/ Activities

       6.      Are you currently employed? If so, please state the name of your employer, how long

you have worked for this employer, your position or job title, your main duties, whether you work

full or part-time, and whether you supervise others and, if so, how many. If you are not currently

employed, please state whether you are: a homemaker, a student, disabled and unable to work,

unemployed or laid off, retired, own your own business, or are self-employed.

       7.      Please provide the following information about your previous three jobs, beginning

with the most recent: the name of your employer, your position or job title, the approximate dates

of your employment, and your reason for leaving.

       8.      If you are now or have ever been married, please describe the employment or

occupation of your present or former spouse.

       9.      If any of your adult children are married, please describe the employment or

occupation of their spouse(s).

       10.     Please describe the most recent employment or occupation of any other adults who

live in your household.

       11.     What are your leisure-time activities or interests?

       12.     Do you hold any office or title in any civic, social, religious, political, professional

or trade organizations?

Experience with Law and the Courts

       13.     Have you or any immediate family member (spouse, parent, child or sibling) or any

close friend ever attended law school, taken paralegal course work, or received any other type of

training in law, law enforcement, or criminal justice? If YES, please explain.


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    Case 1:05-cr-00394-RBW            Document 182         Filed 11/13/2006       Page 3 of 11



       14.     Are you and attorney, or do you have any immediate family members (spouse, parent,

child or sibling) or any close friends who are attorneys? If YES, please state each attorney's name,

type of practice, and relationship to you:

       15.     Have you or any immediate family member (spouse, parent, child or sibling) or any

close friend ever been employed by, or made any application for employment with, any local, state

or federal law enforcement agency or any prosecutor's office? If YES, please provide the name of

each person, his or her relationship to you, and the agency or office for which he or she work or

worked.

       16.     Have you or any immediate family member (spouse, parent, child or sibling) or any

close friend ever been employed by, or made an application for employment with, any organization

or firm involved in criminal defense work, or ? If YES, please provide the name of each person, his

or her relationship to you, and the agency or office for which he or she work or worked.

       17.     Have you or any immediate family member (spouse, parent, child or sibling) or any

close friend ever been employed by, or made an application for employment with, any organization

or firm that provides investigation or other services to prosecutors or defense attorneys, or people

charged with crimes? If YES, please provide the name of each person, his or her relationship to you,

and the agency or office for which he or she work or worked.

       18.     Do you feel that you might give more or less weight to the testimony of law

enforcement agents than to that of other witnesses? If YES, please explain.

       19.     Have you or any immediate family member (spouse, parent, child or sibling) or any

close friend ever been the victim of, or witness to, any kind of crime, whether it was reported to law

enforcement authorities or not? If YES, please state whether the person was a victim or a witness,


                                                  3



    Case 1:05-cr-00394-RBW             Document 182         Filed 11/13/2006        Page 4 of 11



the relationship of the person to you, the type of crime involved, whether the crime was reported to

the police, and whether anyone was ever caught or punished. Did any of these experiences, or

anything you heard about them, leave you with a positive or negative impression of judges, the legal

system, lawyers or law enforcement officers? If so, please explain.

        20.     Have you, or any immediate family member (spouse, parent, child, sibling) or any

close friend been arrested, accused of, or charged with any crime, other than a traffic ticket, including

any charge or accusation you believe was dropped or expunged? If YES, please state the person who

was arrested, accused or charged, the relationship of that person to you, the type of crime involved,

the approximate date of the arrest, accusation or charge, and the outcome of the case. Did any of

these experiences, or anything you heard about them, leave you with a positive or negative

impression of judges, the legal system, lawyers or law enforcement officers? If so, please explain.

        21.     Have you ever been a party to a lawsuit? If YES, please state the approximate date

of the suit, the type of case, whether the case went to trial, and the outcome of the case. Did any of

these experiences leave you with a positive or negative impression of judges, the legal system,

lawyers or law enforcement officers? If so, please explain.

        22.     Have you or any immediate family member (spouse, parent, child, sibling) or any

close friend testified in court in any type of proceeding? If YES, please state the person who

testified, the relationship of that person to you, whether the person was a victim, witness or party,

the type of case, and the approximate date of the testimony. Did any of the above experiences, or

anything you heard about them, leave you with a positive or negative impression of judges, the legal

system, lawyers or law enforcement officers? If so, please explain.




                                                   4



    Case 1:05-cr-00394-RBW            Document 182         Filed 11/13/2006        Page 5 of 11



       23.     Have you ever served on a jury? If YES, please state the approximate date of your

service, the type of case, and whether a verdict was reached. Have you ever served as a jury

foreperson? If YES, please indicate the case in which you so served.

       24.     Have you ever served on a grand jury? If YES, please state where, when and for how

long you served, and whether you served as the foreperson.

       25.     Did any of your experiences as a juror or grand juror leave you with a positive,

negative, or neutral impression of judges, the legal system, lawyers or law enforcement officers?

If YES, please explain.

       26.     Is there anything about your previous experience as a juror that would make you want

to serve, or want not to serve, as a juror again? Please explain.

Experiences with Other Government Departments and Agencies

       27.     Have you, or any member of your immediate family (spouse, parent, child, sibling),

or any close friend ever been employed by, or applied for employment with, any agency or

department of the United States government? If YES, please provide the name of each person, his

or her relationship to you, and the agency or office for which he or she work or worked.

       28.     Have you, or any member of your immediate family (spouse, parent, child, sibling),

or any close friend ever had any legal action or dispute with the United States or any of its agencies,

or any officer, agent or employee of the United States? If YES, please describe your interest and the

nature of the action or dispute.

       29.     Have you or a family member or close friend ever had an experience involving the

FBI, police, or any other law enforcement agency, including being interviewed by or making a report




                                                  5



    Case 1:05-cr-00394-RBW            Document 182         Filed 11/13/2006       Page 6 of 11



to a law enforcement officer? If YES, please explain the approximate time and nature of your

experience.

News Media

       30.     Do you subscribe to or read any newspapers or magazines? If YES, which

newspaper(s) and/or magazine(s) do you subscribe to or read on a regular basis?

       31.     From what source or sources to you receive news on a regular basis (TV, radio,

newspapers, news magazines, newsletters, the internet, conversations with others)?

       32.     If you sit as juror in this case, I will instruct you to avoid exposure to any media

coverage or discussion about he case other than the evidence and argument that you hear in court.

Would you find it difficult to obey such an instruction?

       33.     Have you, or any member of your immediate family (spouse, parent, child, sibling),

or any close friend ever worked as a journalist, or been employed by a newspaper, magazine, or a

television or radio station? If YES, please explain.

Questions Related to this Case

       34.     In the indictment, Mr. Libby is charged with obstruction of justice, perjury, and

making false statements to investigators and a grand jury in connection with an investigation

concerning possible unlawful disclosures to reporters of classified information regarding the

employment of Valerie Plame Wilson, the wife of former Ambassador Joseph Wilson. The

defendant denies that he committed any of the charged offenses, and he is presumed innocent of the

charges against him. Is there anything about the nature of the charges in this case that would affect

your ability to be fair to both the defendant and the government, or to fairly evaluate whether or not




                                                  6



    Case 1:05-cr-00394-RBW              Document 182        Filed 11/13/2006      Page 7 of 11



the government has proven the guilt of the defendant beyond a reasonable doubt? If YES, please

explain.

       35.        Mr. Libby served as Chief of Staff and National Security Adviser to the Vice

President Richard Cheney. Is there anything about that fact that would make it difficult for you to

be fair to both the government and the defendant, or to fairly evaluate whether or not the government

has proven the guilty of the defendant beyond a reasonable doubt? If YES, please explain.

       36.        Have you read, seen or heard any news or editorial coverage about this case? If YES,

have you followed the case closely? Whether you received a little or a lot of information about this

case, would you be able to put everything you have seen, heard, or read about this case aside and

focus only on the evidence presented in court in reaching a verdict?

       37.        Do you know or have any connection with me or any member of my staff? If YES,

please explain.

       38.        Do you know or have any connection with defendant I. Lewis "Scooter" Libby or any

members of his family? If YES, please explain.

       39.        Do you know or have any connection with any of the following lawyers for the

defense or any members of their staff? If YES, please explain.

       William H. Jeffress              Joseph A. Tate         James Lewis Brochin

       Theodore V. Wells                K.C. Maxwell           Alexandra M. Walsh

       John D. Cline                    Alex Joseph Bourelli




                                                   7



    Case 1:05-cr-00394-RBW              Document 182      Filed 11/13/2006        Page 8 of 11



       40.     Do you know or have any connection with any of the following lawyers for the United

States or any members of their staff?

       Patrick J. Fitzgerald            Ronald R. Roos        Peter R. Zeidenberg

       Debra Riggs Bonamici             Kathleen M. Kedian

       41.     Do you know or have any connection with any of the following special agents of the

Federal Bureau of Investigation, who worked on this case? If YES, please explain.

       Deborah S. Bond                  John C. ("Jack") Eckenrode            Kirk D. Armfield

       42.     Do you know or do you have any connection with any of the following journalists,

who may testify as witnesses in the trial? If YES, please explain.

       Judith Miller                    Matthew Cooper                        Tim Russert

       43.     Do you know or do you have any connection with any of the following persons, who

may testify as witnesses in the trial? If YES, please explain.

       [Supplement with witness list agreed to by both parties as of the date of jury selection]

Questions Related to Your Ability to Serve as Juror

       44.     Do you have any difficulty reading, speaking or understanding the written or spoken

English language? If YES, please explain.

       45.     Do you have any medical condition or physical problem, including a problem with

your hearing or eyesight, that might affect your ability to or listen to witnesses, view exhibits, or

otherwise affect your service as a juror? If YES, please explain.

       46.     Do you take any medications that affect your thinking, attention, concentration or that

might affect your service as a juror? If YES, please explain.




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    Case 1:05-cr-00394-RBW            Document 182         Filed 11/13/2006        Page 9 of 11



       47.     If you serve on the jury, during the trial, I will instruct you about the applicable law.

It is your obligation to follow my instructions, whether you agree with the law or not. Do you have

any difficulty with the notion that you must accept and follow the Court's instructions as they are

given to you? If YES, please explain.

       48.     Do you have personal, religious, philosophical or other beliefs that would make it

difficult for you to sit in judgment of another? If YES, please explain.

       49.     Is there any other matter that you think the Court or the parties should know about

you? If YES, please explain.

                                                       Respectfully submitted,


                                                                 /s/
                                                       PATRICK J. FITZGERALD
                                                       Special Counsel
                                                       DEBRA RIGGS BONAMICI
                                                       KATHLEEN M. KEDIAN
                                                       Deputy Special Counsels

                                                       Office of the United States Attorney
                                                       Northern District of Illinois
                                                       219 South Dearborn Street
                                                       Chicago, Illinois 60604
                                                       (312) 353-5300

Dated: November 13, 2006




                                                  9



    Case 1:05-cr-00394-RBW           Document 182        Filed 11/13/2006       Page 10 of 11



                                 CERTIFICATE OF SERVICE

        I, the undersigned, hereby certify that on this 13th day of November, 2006, I caused true and
correct copies of the foregoing to be served on the following parties by electronic mail:

                           William Jeffress, Esq.
                           Baker Botts
                           The Warner
                           1299 Pennsylvania Avenue, N.W.
                           Washington, DC 20004-2400
                           Facsimile: 202-585-1087

                           Theodore V. Wells, Esq.
                           Paul Weiss
                           1285 Avenue of the Americas
                           New York, NY 10019-6064
                           Facsimile: 212-373-2217

                           Joseph A. Tate, Esq.
                           Dechert LLP
                           4000 Bell Atlantic Tower
                           1717 Arch Street
                           Philadelphia, PA 19103-2793
                           Facsimile: 215-994-2222

                           John D. Cline, Esq.
                           Jones Day
                           555 California Street
                           San Francisco, CA 94104
                           Facsimile: 415-875-5700

                                                              Patrick J. Fitzgerald
                                                              Special Counsel
                                                              U.S. Department of Justice
                                                              1400 New York Ave., N.W.
                                                              Washington, D.C. 20530
                                                              202-514-1187

                                                              By:      /s/
                                                              Debra Riggs Bonamici
                                                              Deputy Special Counsel



Case 1:05-cr-00394-RBW   Document 182   Filed 11/13/2006   Page 11 of 11




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