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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Civil Action No. 1:20-mc-00016-ABJ

IN RE: JUROR QUESTIONNAIRES IN DECLARATION OF

UNITED STATES V. STONE DANIELLE K. CITRON

Hon. Amy Berman Jackson

DECLARATION OF DANIELLE K. CITRON

Pursuant to 28 U.S.C. § 1746, I, Danielle K. Citron, hereby declare as follows:

1. I am a Professor of Law at Boston University School of Law. I teach and write

about information privacy, free expression, and civil rights. I was named a

MacArthur Fellow in 2019 based on my work on cyber stalking and sexual

privacy. I have published numerous articles in research journals such as Yale

Law Journal, Georgetown Law Technology Review, and the Harvard Law

Review Forum. My recent books and articles include: “Why Combating Online

Abuse Is Good For Free Speech,” in Free Speech in the Digital Age (Oxford

University Press, 2019); “Cyber Mobs, Disinformation, and Death Videos: The

Internet As It Is (And As It Should Be),” review of Nick Drnaso, Sabrina,

Drawn & Quarterly (2018), 118 Michigan Law Review (forthcoming); “Deep

Fakes: A Looming Crisis for Privacy, Democracy, and National Security,” 107

California Law Review 1753 (2019); “Addressing Cyber Harassment: An

Overview of Hate Crimes in Cyberspace,” 6 Case Western Reserve Journal of

Law, Technology & the Internet 1 (2015); Hate Crimes in Cyberspace (Harvard

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University Press, 2014); and “Civil Rights in Our Information Age,” in The

Offensive Internet: Speech, Privacy, and Reputation (Harvard University Press,

2010).

2. I also serve as the vice president of the Cyber Civil Rights Initiative, a nonprofit

organization devoted to the protection of civil rights and liberties; on the board

of directors of the Electronic Privacy Information Center and the Future of

Privacy Forum; and on the advisory boards of the Anti-Defamation League’s

Center for Technology and Society and Teach Privacy. I also advise tech

companies on online safety and civil liberties.

3. Based on my scholarship regarding the interaction of human behavior, culture,

and law in the digital age, I am profoundly familiar with the broad variety of

destructive online behaviors, including cyber stalking and doxxing – the practice

of releasing personal information online to encourage harassment. I have

studied and written about the devastating impact that cyber-mob harassment can

have on individuals and society, and the toxic nature of certain online

environments and their ability to supercharge human biases. One of the harmful

impacts of cyber-mob harassment is silencing victims and chilling their exercise

of free speech, since victims often withdraw from online activities and have

difficulty expressing themselves in the face of such harassment. I have also

studied and written about the breathtaking velocity with which disinformation

can spread online, and the consequences of such activity. For example, I have

written about how the smears of Alex Jones’ Infowars against the Sandy Hook

families took no time to spread to message boards like 4chan and 8chan, which

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further disseminated damaging lies about the parents and their personal

information. In short order, the families received death threats and their personal

information was exposed.

4. Based on my academic focus on the field of cyber stalking and online privacy, I

am also thoroughly familiar with the current Administration’s “Report of the

Attorney General’s Cyber Digital Task Force,” released in July 2018. My

scholarship is in accord with the descriptions and conclusions of the Report to

the effect that “cyber-enabled stalking and harassment are other particularly

pernicious cyber threats against individuals … Cyberstalking includes any

course of conduct or series of acts taken by the perpetrator that places the victim

in reasonable fear of death or serious bodily injury, or causes, attempts to cause,

or would reasonably be expected to cause substantial emotional distress to the

victim or the victim’s immediate family. Prohibited acts include repeated,

unwanted, intrusive, and frightening communications from the perpetrator by

phone, e-mail, or other forms of communication; harassment and threats

communicated through the Internet, such as social media sites; and the posting

of information or spreading rumors about the victim on the Internet. Cyber-

enabled harassment, by contrast, involves more generalized threats to victims,

and includes swatting and doxxing …. Doxxing involves broadcasting personal

information about the victim on the Internet, exposing him or her to further

harassment by others.”

5. Sidley Austin LLP has retained me as a pro bono online privacy expert to

provide my opinion as to the realistic risks that the jurors and alternates for the

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criminal trial of Roger Stone could face if they were publicly identified, or if

they had the private, sensitive, intimate or identifying contents of their juror

questionnaires released into the online environment surrounding the Stone trial.

6. My opinion here is based on the following facts that I have been asked to

assume are true:

a. As part of the voir dire process to empanel a jury, the prospective jurors

completed questionnaires (a blank sample of which is attached to this

Declaration) that required them to describe truthfully and in detail various

private, sensitive, personal views and other intimate matters about

themselves and their children, and other family members and close

associates.

b. In addition, the prospective jurors were required to provide detailed

information about their current place of employment and past employment

and other biographical or identifying details.

c. The jurors were provided express assurances by the Court that their names

and identities would not be publicly disclosed, and that only the Court,

counsel for the defense (i.e., for the defendant Mr. Stone) and the

government prosecutors would be provided with the contents of their

completed juror questionnaires.

d. Based on the Court’s direction to complete the questionnaires fully and

truthfully, and its assurances of privacy and confidentiality, the jurors

responded by providing highly private, sensitive, intimate or identifying

information such as:

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i. Names of family members and friends

ii. Detailed employment information for juror, juror’s spouse or

partner, and juror’s children, including employment for the federal

government or organizations dependent on federal government

funding

iii. Name and description of family members employed at law

enforcement agencies

iv. Name and description of family members’ military service

v. Name and description of family members employed in legal field

vi. Religious and personal organizational affiliations

vii. Case name and description of personal family law case to which

juror was a party

viii. Description of violent crimes to which juror was a witness, victim,

or friend of the victim, including childhood assaults

ix. Description of family members’ criminal arrests and convictions

e. In addition to such private or identifying information, the jurors also

responded to a number of general questions, and “multiple choice” and

“check box” inquiries of a more generic nature (which can be seen in the

attached blank questionnaire).

f. The questionnaires were provided in full to counsel for the defense and

prosecution for purposes of examining the jurors during voir dire, and the

voir dire was conducted in public in open court. As a result at least of such

public voir dire, certain information about certain individual jurors has

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already became the subject of derisive online commentary by apparent

sympathizers of the defendant Mr. Stone.

g. Attention to the Roger Stone criminal trial, and his subsequent conviction,

have become highly polarized subjects on the internet and Twitter. For

example, Alex Jones of infowars.com, Jacob Engels of

thegatewaypundit.com, and Michael Cernovich (@cernovich on Twitter)

have published items, podcasts or tweets on the internet purporting to “out”

certain jurors, their current and past government employment, purported

“corruption,” and other aspersions that could only be viewed as intending

to paint the jurors in a highly derogatory, conspiratorial light. Even the

President has tweeted about the Roger Stone jury.

h. Two of the Roger Stone jurors have chosen to identify themselves, but only

one of these two has engaged in public commentary about his service on

the jury and the jurors’ process of deliberation.

i. I understand that all of the jurors, including the two who have disclosed

their own names, strongly desire to maintain the privacy and

confidentiality of their juror questionnaires.

j. The jurors relied on express assurances of privacy and confidentiality, and

believed that their questionnaires would only be provided to the Court,

counsel for the defense (Mr. Stone) and the government prosecutors for

their use only to conduct voir dire examination regarding the content of

their questionnaires in open court. The jurors submitted to public

questioning regarding their questionnaires.

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k. All of the jurors reside in the District of Columbia.

7. Based on the above facts that I have been asked to assume for purposes of this

Declaration, together with my decades of academic scholarship in the field of

cyber stalking and online privacy, and my review of various online postings

about the jurors in the Roger Stone trial (listed in the appendix to this

Declaration), it is my opinion that:

a. The Roger Stone trial and conviction presents a highly charged cultural

event of a similar type that occurred with respect to Sandy Hook, the

Parkland shooting, the Charlottesville protests and other deeply polarized

events that have in the past stimulated online harassment and conspiracy

theories fomented cyber-mobs.

b. If the names of the jurors who deliberated in the Roger Stone trial were

made public, I believe their identities and life stories – and those of their

children, family, friends and close associates – would likely in short order

go viral in certain sectors of the internet and potentially trigger a cyber-

mob reaction.

c. Disclosing the identity of the jurors (and potentially their families, friends

and close associates) or the contents of their juror questionnaires would, in

my opinion, likely transform the jurors (and potentially their families,

friends and close associates) into victims of an online information cascade

that occurs when people pass on what others say without checking the

information’s veracity. This process typically leads to harassment and

conspiracy theories similar in nature to what was experienced by the Sandy

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Hook families, and what is described in the 2018 Report of the Attorney

General’s Cyber Digital Task Force as causing a “reasonable fear” of

injury or substantial emotional distress, including possible “repeated,

unwanted, intrusive, and frightening communications” and “harassment

and threats communicated through the Internet, such as social media sites;

and the posting of information or spreading rumors about the victim on the

Internet.”

d. Disclosure of the private, sensitive, intimate or identifying information

from the jurors’ questionnaires could likely subject certain jurors to the

possibility of retaliation in the workplace, for example, if they were

employed in a workplace where supervisors were partisans of the internet

conspiracy theories levelled against those jurors. This could be an

especially serious and realistic risk where jurors or their family members

are current government employees working in a partisan workplace

environment.

e. Disclosure of the private, sensitive, intimate or identifying information

from the jurors’ questionnaires would likely also chill the jurors’ own

speech and free expression by causing them to retreat from their own social

media presence and communications in order to avoid further abuse online

and attacks by cyber-mobs.

f. I do not believe it is reasonably possible to protect the jurors’ privacy and

identity by merely removing the obviously identifying information from

publicly released versions of the questionnaires – i.e., redacting name,

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address, place of employment, etc. Considerable academic scholarship,

regulatory requirements and practical guidance has addressed the subject of

the ease of personal re-identification of individuals based on a relatively

small number of data points.

g. In my opinion, and based on my extensive scholarship focused on the

intense motivations and capabilities of cyber-mobs, I believe that the

disclosure of jury questionnaires containing particularly significant and

highly personal elements of the jurors’ life stories would not be

realistically consistent with protecting the jurors’ anonymity. I believe this

even if the Court made an effort to remove the readily identifying details

like name, email, home address and place of employment. Rather, the

intimate – and the quotidian – details of the jurors’ lives that are contained

in the questionnaires would easily provide more than enough information

for layperson bloggers to re-identify the jurors – all of whom live in the

District of Columbia – without the need to involve any complex data

science.

h. If the jurors’ anonymity is sacrificed, or their private, sensitive or intimate

data is made public, it is my opinion that some, many or all of them will

face cyber retribution and harassment online and, if they are lucky, only

online.

i. These jurors will be less likely to approach future jury service with the

same sense of duty and respect for the legal system, and confidence that

the U.S. government is willing and able to follow through on its privacy

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commitments and obligations. Prospective jurors called to serve in

judgment of other defendants will be similarly chilled in the discharge of

their duties.

j. Protecting juror privacy is a fundamental interest of our society along with

the right of public access to criminal trials. Here, as I understand it, the

public has had near total access to this trial and pre-trial voir dire

proceedings. If the juror questionnaires of these jurors were released in

toto, or even substantially redacted, juror privacy would be nearly totally

extinguished.

Conclusion

For the reasons expressed above, it is my opinion that this Court, and the legal system,

should exercise its collective responsibility to protect the privacy and security of the

jurors by not publicly releasing the private, sensitive, intimate or identifying contents of

the jurors’ questionnaires.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: April 14, 2020 /s/ Danielle K. Citron

Danielle K. Citron

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APPENDIX

InfoWars video: “#EpsteinDidntKillHimself Takes Over the Planet As A Global

Awakening Accelerates,” Alex Jones Show, InfoWars (Nov. 6, 2019),
http://tv.infowars.com/index/display/category/dailyshows/page/2/id/10153.
o The portion transcribed in the Media Matters 11/6 article begins at 13:45.
“Oh, but wait till you hear who this woman that’s going to be, you know,
the jury foreman. And wait till you hear where she came from. Bill and
Melinda Gates, yeah.”
WaPo article: Deanna Paul, Alex Jones threatened to name a Roger Stone juror.
Experts say that might be jury tampering.” Wash. Post (Nov. 7, 2019),
https://www.washingtonpost.com/politics/2019/11/07/alex-jones-threatened-
name-roger-stone-juror-experts-say-that-might-be-jury-tampering/.
Salon article: Igor Derysh, “We’ve got her name”: Alex Jones claims to out
potential Roger Stone juror – and gets it wrong, salon (Nov. 7, 2019),
https://www.salon.com/2019/11/07/weve-got-her-name-alex-jones-claims-to-out-
potential-roger-stone-juror-%E2%81%A0-and-gets-it-wrong/.
Daily Beast article: Alex Jones Goes on Tirade Against Roger Stone Jurors, The
Daily Beast (Nov. 7, 2019), https://www.thedailybeast.com/alex-jones-goes-on-
tirade-against-roger-stone-jurors.
Media Matters 11/5 article: Alex Jones is trying to out the identity of a potential
Roger Stone trial juror with the help of Stone’s assistant, Media Matters (Nov. 5,
2019), https://www.mediamatters.org/roger-stone/alex-jones-trying-out-identity-
potential-roger-stone-trial-juror-help-stones-assistant.
Media Matters 11/6 article: Alex Jones vows to release name of potential juror
in Roger Stone trial, Media Matters (Nov. 6, 2019),
https://www.mediamatters.org/alex-jones/alex-jones-vows-release-name-
potential-juror-roger-stone-trial.
Gateway Pundit article: Jacob Engels, Stunning: Corrupt Roger Stone Jury
Forewoman Is Connected To Court Appointed Lawyer, Gateway Pundit (Mar. 19,
2020), https://www.thegatewaypundit.com/2020/03/stunningcorrupt-roger-stone-
jury-forewoman-is-connected-to-court-appointed-lawyer/.

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EXHIBIT A
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Instructions for Jury Questionnaire

This questionnaire is designed to obtain information about your background as it relates
to your service as a juror in this case. We are using it to shorten the jury selection process. The
purpose of these questions is to determine whether prospective jurors can decide this case fairly,
based solely on the evidence presented at trial and the instructions on the law given by the judge.
The parties and the Court have agreed that all information contained in this questionnaire will be
kept confidential; to the extent the Court is ever required to release any responses in the
questionnaires, your name will not be publicly released.
Please write your assigned juror number at the top of each page. Respond to each
question. Your candor and honesty are necessary so that both the prosecution and the defense
will have a meaningful opportunity to select an impartial jury. Your cooperation is of vital
importance.
You are sworn to give true and complete answers, and those answers will be available
only to the Court and the parties in this case.
From this day forward, until you have been formally excused from service, you are
instructed not to communicate in person, in writing, or electronically about this case or the
questionnaire with anyone, including your family and fellow jurors. Also, you should not go
online or look at any source to learn more about the charges, the defendant, or any participant in
the case.
Please fill out the entire questionnaire. Do not leave any questions blank. If a question
does not apply to you in any way, write “N/A” rather than leaving the form blank.

PLEASE PRINT LEGIBLY - PLEASE USE ONLY BLACK OR BLUE INK

(NO PENCILS)
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JUROR NUMBER: ________________

JURY QUESTIONNAIRE

IN COMPLETING THIS QUESTIONNAIRE, PLEASE USE THE SPACE PROVIDED

AFTER EACH QUESTION. IF YOU NEED MORE SPACE, PLEASE USE THE PAGES
PROVIDED AT THE END OF THE QUESTIONNAIRE, INDICATING THE NUMBER
OF THE APPLICABLE QUESTION.

1. a. Are you able to read, write and understand the English language?

Yes ___ With Difficulty___ No ____

b. Are you able to complete this questionnaire without another person’s assistance?
Yes ___ No ___

IF YOUR ANSWER TO EITHER QUESTION 1(a) or 1(b) IS “NO,” PLEASE SIGN THE
LAST PAGE OF THE QUESTIONNAIRE AND RETURN IT WITHOUT ANSWERING
ANY OTHER QUESTIONS.

BACKGROUND INFORMATION
2. Please provide the following personal information:

Age: ______

Gender: ______

3. What is your marital status? (Check all that apply.)

Single and never married ______

Married ______
Separated or divorced ______
Divorced and remarried ______
Living with significant other or domestic partner ______
Widow or Widower ______

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JUROR NUMBER: ________________

EDUCATION AND EMPLOYMENT

Education
4. Check the highest level of education for you and your spouse or significant other:

You Spouse/Significant Other

a. Grade school or less _____ _____
b. Some high school _____ _____
c. High school graduate _____ _____
d. Technical or business school _____ _____
e. Some college _____ _____
f. College degree _____ _____
g. Graduate degree (and describe area) _____ _____ Area: _______________

Employment
5. Are you employed?

_____ Yes _____ No

6. a. If employed, what is your current occupation / job title?

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
b. Name of employer:

________________________________________________________________________
c. How long have you been employed at your current job?

________________________________________________________________________

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JUROR NUMBER: ________________

7. If you are unemployed, please describe any other responsibilities you may have
(childcare, school, etc.).

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

8. If you are retired or between jobs, what type of work had you been doing?

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

9. If you live with a spouse or significant other, is that person employed?

_____ Yes _____ No

10. If employed, what is his or her current occupation / job title?

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

11. Name of the employer:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

12. If you are a student now, please describe briefly your area of study:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

13. Have you or a close friend or family member ever worked in any aspect of the legal field,
as a lawyer, prosecutor, criminal defense attorney, legal secretary, paralegal, court
reporter, investigator, law clerk, judge, etc.?

Yes ___ No ___

If yes, please explain:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

14. Have you or a close friend or family member ever applied for employment with, was
employed by, or received training by any local, state, or federal law enforcement agency,
including any of the following:

1) Department of Justice (DOJ)

2) Federal Bureau of Investigation (FBI)
3) U.S. Attorney’s Office
4) Bureau of Alcohol, Tobacco, Firearms
5) Internal Revenue Service (IRS)
6) Department of Homeland Security (DHS)
7) U.S. Marshal’s Service
8) U.S. Immigrations & Customs
9) U.S. State Department
10) U.S. Bureau of Prisons (BOP)
11) Central Intelligence Agency (CIA)
12) Defense Intelligence Agency (DIA)
13) National Security Agency (NSA)
14) National Geospatial Intelligence Agency
15) U.S. Secret Service
16) Transportation Security Administration
17) Federal, state or local prison or jail
18) Federal, state or local courthouse
19) Federal, state or local prosecutor’s office

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JUROR NUMBER: ________________

If yes to any of the above, please identify the person involved and the agency, and state
the approximate dates of the employment or training, and the position or involvement:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

15. Do you have any opinions or beliefs concerning law enforcement organizations in
general, including the Federal Bureau of Investigation (FBI) or the Department of Justice,
or the Special Counsel’s Office within the Department of Justice, that would affect your
ability to evaluate the evidence fairly and impartially?

Yes ___ No ___

If yes, please explain:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

16. In this case, the United States is represented by the U.S. Attorney’s Office for the District
of Columbia. The investigation that led to the charges in this case was conducted by
Special Counsel Robert S. Mueller, III. The U.S. Attorney’s Office is, and the Special
Counsel’s Office was, a part of the U.S. Department of Justice. Is there anything about the
fact that the Special Counsel’s Office, the U.S. Attorney’s Office, or the Justice
Department is or was involved in this case that affect your ability to be fair and impartial
in this case and base your decision solely on the evidence presented and the Court’s
instructions on the law?

Yes ___ No ___

If yes, please explain:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

17. Check to indicate whether you or your spouse (significant other, domestic partner) has
taken any courses, received any training, or sought or obtained employment, in any of
these fields:
You Spouse
Security/Intelligence ________ _________
International Relations ________ _________
Journalism/Media/Communications ________ _________

For any item checked, please describe the training or employment:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

ORGANIZATIONAL AFFILIATIONS AND ACTIVITIES

18. Are you currently, or have you ever been, a member or regular participant in any civic,
social, union, professional, business, fraternal, recreational or other community group or
charitable organizations?

Yes ___ No ___

If yes, please list the names of those groups or organizations, your role and how long a
member:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

PRIOR JURY SERVICE

19. Have you ever served on a grand jury or jury in a trial within the past 10 years?

Yes ___ No ___

If yes, how many times have you served as a juror in a trial? ______

If yes, have you ever served as a foreperson? ______

If yes, how many times? ______

If yes, for each trial jury service, please indicate:

Federal Civil or Charge or Verdict

Year or State Criminal Type of Case Reached

_______ _________ ___________ ____________________ Yes No

_______ _________ ___________ ____________________ Yes No

_______ _________ ___________ ____________________ Yes No

_______ _________ ___________ ____________________ Yes No

If you served as a grand juror, how many times did you serve as a grand juror? _____

20. If you served as a juror, is there anything about your previous experience as a juror that
would affect your ability to serve as a juror in this case?

Yes ___ No ___

If yes, please explain:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

NEWS AND SOCIAL MEDIA

21. If you follow local or national news, what are your primary sources for local and national
news and information? (Check all that apply)

I do not follow local or national news ____

Newspapers (including online) ________ TV/cable ________ Blogs/websites ________
Social Media ________ Radio ________ News magazines ________
Word of mouth/conversations ______ Other sources (specify) _____________________

Please identify by names your primary sources of news and information:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

22. Do you listen to political commentators on TV or talk radio?

Yes ___ No ___

If yes, please list the commentators you listen to:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

23. Have you written or posted anything for public consumption about the defendant, the
House Permanent Select Committee on Intelligence investigation into Russian
interference in the 2016 presidential election, or the investigation conducted by Special
Counsel Robert Mueller?

[For purposes of this question, writing “for public consumption” includes blog posts,
articles, or posts on internet sites that are accessible to the general public.]

Yes ___ No ___

If yes, please describe when and where you did so and the subject of your comments:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

24. Have you or any close friend or family member ever run for or held a political office in
the federal, state, or local government?

Yes ___ No ___

If yes, would anything about that person’s running for or holding political office cause
you to form an opinion about the defendant’s guilt or innocence in this case or affect
your ability to be fair to both sides?

Yes ___ No ___

If yes, please explain:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

25. How closely have you followed media reports relating to investigations into Russian
interference in the 2016 election?

Very Closely ______ Somewhat Closely ______ Not too closely ______ Not at all _____

26. To assure that the decision of jury in this case is not based upon influences outside the
courtroom, the Court has instructed you that you must avoid reading about the case in the
newspapers or listening to any radio or television reports concerning this case including
news coverage or communications on the internet or social media. And, you may not
discuss or communicate about this case with your family, friends or co-workers or
anyone else including on the internet or social media. Also, until you retire to deliberate,
you may not communicate about this case with your fellow jurors. If you are selected as
a juror and this instruction continues until the end of the trial, you be able to follow these
instructions?

Yes ___ No ___

If no, please explain:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

KNOWLEDGE OF TRIAL PARTICIPANTS OR THE CASE

This case arises out of events that occurred in 2016-2018, including the testimony of Roger
Stone before the House Permanent Select Intelligence Committee (HPSCI) on September 26,
2017. There is nothing wrong with having heard or read something about this case, but it is
important to this process that you truthfully and fully answer the following questions concerning
your knowledge about the case and trial participants, if any.

27. Have you read or heard anything about the defendant Roger Stone, about any statements
made by or attributed to Mr. Stone, or about this case? If so, please describe what you
have read or heard and the source of the information.
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

28. Do you or anyone close to you have any connections to any of the following individuals?
If so, you please explain below:

The Court
United States District Judge Amy Berman Jackson Yes ___ No ___

Assistant United States Attorneys

Adam Jed Yes ___ No ___
Jonathan Kravis Yes ___ No ___
Michael Marando Yes ___ No ___
Aaron Zelinsky Yes ___ No ___

Counsel for the Defendant

Robert Buschel Yes ___ No ___
Tara Campion Yes ___ No ___
Bruce Rogow Yes ___ No ___
Chandler Routman Yes ___ No ___
Grant Smith Yes ___ No ___

The Defendant
Roger Stone Yes ___ No ___

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JUROR NUMBER: ________________

If yes, please explain:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

29. These are the names of people who may be witnesses in the case or who may be
discussed during the trial.

1) Julian Assange 17) David Lugo

2) Jason Aubin 18) Theodore Malloch
3) Steve Bannon 19) Paul Manafort
4) William Binney 20) Rebekah Mercer
5) Zachary Blevins 21) Andrew Miller
6) Matthew Boyle 22) Tyler Nixon
7) Michael Caputo 23) Sam Nunberg
8) Peter Clay 24) John Podesta
9) Hillary Clinton 25) Alexandra Preate
10) Jerome Corsi 26) Erik Prince
11) Randy Credico 27) Bill Samuels
12) Richard Gates 28) Michael Strum
13) Jason Fishbein 29) Jason Sullivan
14) David Gray 30) Michelle Taylor
15) John Kakanis 31) Donald Trump
16) Margaret Kunstler

If you know any of those individuals personally, please identify which ones and explain
how you know them.
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

30. Please indicate if you already have an opinion about any of those individuals, or if the
fact that they may be involved in the case would make it difficult for you to be fair and
impartial to both sides?
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

31. Have you or a close friend or family member ever been employed or had any association
or connection with Congress or a congressional committee?

Yes ___ No ___

If yes, please explain the employment, association or connection:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

32. Did you work or volunteer for any 2016 presidential campaign?

Yes___ No____
33. Have you or any close friend or family member participated in, or had any connection
with any government agency, group, organization, committee or subcommittee, public or
private group or organization, including any media group or organization that participated
in, any investigation or inquiry into the circumstances surrounding Russian interference
in the 2016 presidential election?

Yes ___ No ___

If yes, please explain:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

34. Have you formed or expressed any opinion about Mr. Stone, the charges in this case, or
about his guilt or innocence in this case?

Yes ___ No ___

35. Some of the witnesses in this case may be people who were involved in crimes
themselves. They would testify as part of a cooperation agreement with the
government, or as part of a guilty plea, or under an order from the Court giving them
immunity. Is there anything about that circumstance that will make it difficult for you to
evaluate their testimony fairly and impartially in accordance with the Court’s
instructions?

Yes ___ No ___

If yes, please explain:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

EXPERIENCE WITH THE COURTS AND CRIMINAL PROCESS

36. Within the past ten years, have you or a close friend or family member been the victim of
a crime, reported or not?

Yes ___ No ___

37. If yes, for each incident please provide the following information: type of crime, who was
affected (you or the relationship of the person to you), when the crime occurred, whether
anyone was arrested, and if so, the outcome of the case:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

38. If yes, do you feel that the person was treated fairly by the government agency involved?
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
_______________________________________________________________________

39. Within the past ten years, have you or a close friend or family member been a witness to
a crime?

Yes ___ No ___

If yes, please explain:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

40. Within the past ten years, have you or a close friend or family member been subpoenaed
to be a witness, or did you or they testify as a witness in any court proceeding, hearing, or
trial, including a criminal case?

If yes, please explain:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

41. Within the past ten years, have you or a close friend or family member been arrested for,
charged with, prosecuted for, or convicted of any crime other than a traffic ticket?

Yes ___ No ___

If yes, please explain who (in relation to you), when, and what happened:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

If yes, do you feel that you or your friend or family member was treated fairly?
Yes ___ No ___

42. Within the past ten years, have you or a close friend or family member been the subject
of any other kind of law enforcement investigation or administrative enforcement
proceeding?

Yes ___ No ___

43. If yes, please describe the subject matter of the investigation, the government agency
involved, and the outcome.
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

44. Do you feel that you, your family member, or close friend was treated fairly by the
government agency involved?
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

45. Apart from jury service, have you ever been involved in any legal proceeding, in any
capacity, for example as a plaintiff, defendant, victim, lawyer, witness, or expert?

Yes ___ No ___

46. If yes, please state when and explain why you appeared in court:
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

47. If yes, did the legal process in that instance operate fairly in your opinion?
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

CRIMINAL JUSTICE SYSTEM & LEGAL PRINCIPLES

48. The judge will instruct you that the charges in this case include: obstruction of an official
proceeding, making false statements, and witness tampering. Is there anything about the
nature of the charges alone that would affect your ability to be fair?

Yes ___ No ___

49. Jurors are the sole judges of the facts. However, the jury must follow the principles of
law as instructed by the judge. The jury may not follow some rules of law and ignore
others. Even if the jury disagrees or dislikes the rules of law or does not understand the
reasons for some of the rules, it is their duty to follow them. Do you have any personal
beliefs that would make it difficult to follow the Court’s legal instructions, whatever they
may be?

Yes ___ No ___

50. If, during the course of jury deliberations, a fellow juror should suggest that you
disregard the law or the evidence and decide the case on other grounds, would you, as a
juror, be able to reject that suggestion and abide by your oath to this court to decide the
case solely on the evidence and law as the court has instructed you to do, without regard
to sympathy, bias or prejudice?

Yes ___ No ___

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JUROR NUMBER: ________________

CONCLUDING QUESTIONS

51. Do you have any personal reason that makes you want to serve as a juror in this case, or
do you have any personal interest in the outcome of the case?

Yes ___ No ___

If yes, please explain:

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

52. Do you have any moral, religious, or ethical beliefs that prevent you from sitting in
judgment of another person?

Yes ___ No ___

53. The trial in this case may last approximately two (2) weeks, and could run longer. The
typical trial day lasts from 9:30 a.m. to 4:30 or 5:00 p.m., with breaks in the morning and
afternoon and a lunch break for approximately an hour. Monday through Friday. If there
is any reason why you could not maintain that schedule, or you could not be present and
give the matter your full attention during the period beginning November 5, 2019, and
ending approximately November 20, 2019, please explain.

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

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JUROR NUMBER: ________________

54. Do you have any physical or medical condition, or are you taking any medication on a
regular basis that would make it unusually difficult for you to serve as a juror in this case
or to sit for the periods of time described in the previous question?

Yes ___ No ___

55. Do you have any difficulty hearing that is not corrected with a hearing aid or any
difficulty seeing that is not corrected by glasses or contact lenses?

Yes ___ No ___

56. Is there anything about this case, the issues, or the people involved in this case, or any
other reason that has not be been asked about in any other question, that leads you to
believe that you could not be completely fair to both the defendant, Roger Stone, and the
U.S. Government in this case?

Yes ___ No ___

________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

PLEASE GO ON TO THE NEXT PAGE

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JUROR NUMBER: ________________

CERTIFICATION
By signing below, I hereby declare under penalty of perjury that all of the answers to the above
questions are true and correct to the best of my knowledge and belief. I have not discussed my
answers with others or received assistance in completing the questionnaire. I have answered all
of the above questions myself.

___________________________ _____________________________ _______________

Signature Print your full name here Date

Juror Number _______

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