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Juror Questionnaire in Short Creek Trial
Juror Questionnaire in Short Creek Trial
JUROR #________
UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
) NO. 12-cv-8123
)
)
) CONFIDENTIAL JUROR
) QUESTIONNAIRE
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Only the Court and the attorneys will use the information that you give in response to this
questionnaire. Your responses to this questionnaire will be kept confidential and all parties will
be under orders to maintain the confidentiality of any information they learn in the course of
reviewing these questionnaires.
Please answer each question below as completely and as accurately as you reasonably can.
PLEASE COMPLETE YOUR ANSWERS IN PEN. If there is not enough space for you to
complete an answer, please complete your answer in the blank pages at the end, writing for
example Question No. 5, continued.... Please do not write on the back of any page.
If there is a question that you do not want to answer because of privacy concerns, then
write in the blank by that question the word "privacy." You may need to visit with the Judge and
the attorneys out of the presence of the other potential jurors concerning that question. If you
simply cannot understand a question, then write in the blank by that question the words "do not
understand."
You are expected to sign your questionnaire, and your answers will have the effect of a
statement given to the Court under oath. What is needed is your very best, honest effort to answer
the questions contained in this questionnaire.
The sole purpose of the questionnaire is to encourage your full expression and candor so
that the parties will have a meaningful opportunity to select a fair and impartial jury to try the
issues of the case. Your full cooperation is of vital importance. Thank you for your assistance.
/s/ H. Russel Holland
The Honorable H. Russel Holland
United States District Judge
2.
The Court and the parties estimate that, after a jury is selected, this case may last
approximately 22 trial days. The trial will begin on January 19, 2016 and last until approximately
February 23, 2016. To be on the safe side, therefore, we are requiring that the jurors who serve on
this case must be available through the end of February 2016. Trial will be in session, generally
speaking, from Monday to Thursday from 9:00 a.m. to 4:30 p.m., and Fridays from 9:00 a.m. to
noon. The Court will arrange for hotel accommodations near the courthouse in Phoenix, Arizona.
Jurors are free to return home on Fridays and return to Phoenix on Sunday. Your travel costs will
be reimbursed.
Does the estimated length of the trial preclude you from serving as a juror in this case? Yes___
No____. If yes, briefly explain why.
The Court views service on a jury in a federal civil trial to be one of the highest duties a citizen
owes to the United States. Mere inconvenience or the usual financial hardships of jury service will
be insufficient to excuse a prospective juror.
Do you have an unusual financial hardship or other serious problem that would prevent you from
serving as a juror in this case? Yes____ No_____. If yes, briefly explain the hardship.
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
STATEMENT OF CASE:
The Plaintiff in this case is the United States of America represented by the Department of Justice.
The Defendants are the City of Hildale, Utah; the Town of Colorado City, Arizona; and Twin City
5.
6.
Have you read or heard anything about the facts of this case other than reading this
questionnaire? Yes ___ No ___. If yes, please explain what you have heard or read.
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
7.
Do you think the media has been unfair to any of the Defendants? Yes ___ No ___. If yes,
which Defendant(s) and please explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
8.
Have you read or heard anything in the media or from friends about Warren Jeffs and/or
about the Fundamentalist Church of Jesus Christ of Latter-Day Saints (FLDS Church)? Yes ___
No ___. If yes, please explain what you have heard or read and please identify any media report
you can recall.
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
9.
If you answered yes, to Question No. 8, above, then answer the following: Even though I
have read or heard press reports about Warren Jeffs and about the Fundamentalist Church of Jesus
Christ of Latter-Day Saints (FLDS Church), I feel I can decide the case on the evidence presented
in court and follow the Courts instruction of law.
Strongly Agree
Agree
Disagree
Strongly Disagree
10.
Is there any reason why you feel you cannot be fair and impartial to the Federal
Government/Department of Justice or to the Defendants in this case? ___Yes ___No. If yes, please
explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
11.
How often do you seek leadership positions at work, or in your community and recreational
activities?
Often
Sometimes
Seldom
Never
Agree
Disagree
Strongly Disagree
____ Apartment
___ Rent
____ Own
16.
Educational background of any other adult who lives in your home, including any degrees
or certificates earned:
____________________________________________________________________________
____________________________________________________________________________
___ Homemaker
Someone Close
___
Lawyer, law firm or any court in the state of Arizona or
Utah
___
Crime investigation or law enforcement
___
Government employee (any level of government)
___
health, life, casualty or accidental injury benefits
or programs
If you checked any lines above, please state the relationship of that person to you, the type
and details of employment and the years of employment:
____________________________________________________________________
____________________________________________________________________
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How do you, or does the person close to you, feel about the way the situation was
handled?
________________________________________________________________________
________________________________________________________________________
(c)
In what ways, if any, did any of these incidents affect your views about claims of
discrimination or harassment?
________________________________________________________________________
________________________________________________________________________
32.
Have you or a relative or close friend ever filed any complaint or lawsuit alleging
discrimination of any kind?
___ Yes ___ No
If yes, please explain your answer:
______________________________________________________________________________
______________________________________________________________________________
4
5
No Opinion
6
7
Very Common
10
Age
____
____
____
____
____
Education
______________
______________
______________
______________
______________
Occupation
_________________
_________________
_________________
_________________
_________________
38.
Have you, a close friend or relative ever run for, been elected to, or been appointed to,
public office, or worked in the office of any elected or appointed public official at the federal, state
or local level? Yes ___ No ___. If yes, please describe:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
39.
Have you, a close friend or relative ever worked as a lobbyist or consultant to a company
doing business with a governmental entity? Yes ___ No ___. If yes, please describe:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
40.
How closely do you follow federal, state, and/or local politics? (Choose one)
______ Very closely
______ Somewhat closely
______ Not very closely
______ Not at all
41.
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46.
Have you ever had to appear in court, or in any legal proceeding, including a deposition,
as a plaintiff, defendant, victim, or witness for any reason other than that explained in questions
30 and 31, above? Yes ___ No ___. If yes, please state when and explain why you appeared in
court:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
47.
Which of the following best describes the way you most prefer to work?
______ I like to lead a group of others;
______ I like to work on my own;
______ I like to work with a group where there is no single leader;
______ I like to work in a group with another person leading me.
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Someone Close
___
___
___
___
___
___
___
___
___
___
___
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57.
Have you, a family member or a close friend ever been involved in, or been the target of,
a criminal investigation, or accused of, arrested for, or charged with a crime?
Yes (self) ______
No ______
(a) If yes, without mentioning names, please generally describe the circumstances
surrounding the criminal investigation(s) and your relationship(s) to the person(s)
involved:
_________________________________________________________________
_________________________________________________________________
__________________________________________________________________
(b) If you answered yes, do you feel that the individual who was investigated or charged
was treated fairly by the criminal justice system? Yes __ No ___. If no, without naming
the individual or case, please explain:
__________________________________________________________________
__________________________________________________________________
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58.
From what you have heard or read, do you think money damages from recent lawsuits have
generally been:
___
___
___
___
Too high
About right
Too low
No opinion
59.
Do you support legislative reforms to place caps or limits on the amount of money juries
can award? ___ Yes ___ No. Please explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
60.
The following are types of damages that people can seek money for in a lawsuit. If there
was evidence justifying it, would you be willing to award money for:
Mental anguish?
Pain and suffering?
Emotional Distress?
62.
How would you rate your knowledge of the workings of Federal, State, local or city
governments?
___ Extremely knowledgeable ___ Fairly knowledgeable
___ Somewhat knowledgeable ___ Not at all knowledgeable
63.
I have more negative than positive feelings towards the United States government.
Strongly Agree
Agree
Disagree
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Strongly Disagree
Agree
Disagree
Strongly Disagree
65.
In general, the United States government does more harm than good when it gets involved
in city or state affairs.
Strongly Agree
Agree
Disagree
Strongly Disagree
66.
I think problems that occur in Arizona and Utah are best left to state and local governments
to resolve without the United States government getting involved.
Strongly Agree
67.
Strongly Disagree
Agree
Disagree
Strongly Disagree
Agree
Disagree
Strongly Disagree
68.
Disagree
Agree
69.
I have strong feelings and beliefs that it is wrong for me to sit in judgment of a party in the
justice system.
Strongly Agree
Agree
Disagree
Strongly Disagree
70.
It is not the United States governments business to protect a person from a city infringing
on constitutional rights.
Strongly Agree
71.
Strongly Disagree
Agree
Disagree
Strongly Disagree
73.
Disagree
The Federal government interferes too much with rights of its citizens.
Strongly Agree
72.
Agree
Agree
Disagree
Strongly Disagree
Lawsuits against cities or governmental entities are bad for the economy.
Strongly Agree
Agree
Disagree
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Strongly Disagree
75.
Strongly Disagree
Agree
Disagree
Strongly Disagree
The Federal government should stop telling people how to live their lives.
Strongly Agree
77.
Disagree
Government regulations are almost always a waste of everyones time and money.
Strongly Agree
76.
Agree
Agree
Disagree
Strongly Disagree
People should be able to rely on the government for help when they need it.
Strongly Agree
Agree
Disagree
Strongly Disagree
78.
No matter what evidence is presented, I could never be persuaded to hold a city or town
liable for damages for emotional distress as a result of housing discrimination because the Federal
government should not be interfering with how an Arizona or Utah city manages its affairs.
Strongly Agree
Agree
Disagree
Strongly Disagree
79.
No matter what evidence is presented, I could never be persuaded to award damages for
emotional distress as a result of housing discrimination by a city because the people can simply
move to another town.
Strongly Agree
Agree
Disagree
Strongly Disagree
80.
No matter what the evidence is, I could never award damages for emotional distress as
result of the housing discrimination when the residents chose to live in the community.
Strongly Agree
81.
Agree
Disagree
Strongly Disagree
Agree
Disagree
Strongly Disagree
Disagree
Strongly Disagree
Agree
(c) Anybody who chose to live in Colorado City or Hildale should not be allowed to sue
because they knew what they were getting into when they decided to live there.
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Strongly Agree
Agree
Disagree
Strongly Disagree
82.
Have you ever known anyone who has suffered any type of discrimination?
___ Yes ___ No. If yes, please explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
83.
An individual who engages in polygamy / plural marriage is less trustworthy than an
individual who does not.
Strongly Agree
Agree
Disagree
Strongly Disagree
84.
Have you watched any movies, documentaries, cable television or network shows or news
specials about polygamy and plural marriage (e.g. Sister Wives, Big Love, Polygamy USA,
Prophets Prey, etc.)? Yes____ No_____. If yes, explain which ones:
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
85.
Have you watched any documentaries, cable television or network shows or news specials
about the FLDS Church and/or its practices? Yes____ No____. If yes, explain:
86.
If you have previously visited, heard about, read, or seen information about Colorado City
or Hildale City, what is your opinion of these communities?
87.
Have you previously watched any documentaries cable television or network show or news
about Warren Jeffs? Yes____ No____. If yes, explain:
88.
The FLDS Church is the dominant religion for individuals who reside in Colorado City
and Hildale. Will your opinions regarding the FLDS Church and/or Warren Jeffs impact your
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89.
Will your opinions regarding the FLDS Church and/or Warren Jeffs impact your ability to
review the evidence presented during this trial fairly and impartially? Yes____ No____. If yes,
explain:
90.
Have you or anyone close to you ever been subjected to what you would describe as a
negative encounter with police officers or law enforcement?
___ Yes ___ No
If yes, please describe the incident:
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
91.
Choose the option that best describes your general opinion of police officers or law
enforcement:
1
2
3
4
5
Extremely Low
No Opinion
6
7
Very High
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93.
Have you known anyone who has lived in Hildale, Utah or Colorado City, Arizona?
___ Yes ___ No. If yes, please explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
94.
Have you ever known someone who is or has been a member of the FLDS Church?
___Yes ___ No. If yes, please describe the persons relationship to you and whether the experience
would interfere with your ability to sit as a fair and impartial juror.
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
95.
Do you have any thoughts about claims for money for mental anguish and/or pain and
suffering? ___ Yes ___ No ___ Unsure. If yes, please explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
96.
In a civil case, the burden of proof is by a preponderance of the evidence (more probable
than not), in contrast to a criminal case where the burden of proof is beyond a reasonable
doubt. Would you require greater proof than a preponderance of the evidence in a claim for
damages for emotional distress? _____Yes ___No. If yes, please explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
97.
The United States is the Plaintiff in this case. Would you require the United States to meet
a higher burden of proof than the preponderance of the evidence simply because it is the Federal
government? ____Yes ___No. If Yes, please explain:
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
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107. Do you belong to any clubs, associations, or civic groups such as, but not limited to,
Kiwanis, Rotary Club, Exchange Club, Knights of Columbus, Veterans of Foreign Wars,
American Legion, American Civil Liberties Union, National Rifle Association, League of Women
Voters, or any other organization?
___ Yes ___No. If yes, please list those to which you belong.
____________________________________________________________________________
____________________________________________________________________________
____________________________________________________________________________
108. Are you a member (or affiliated in any way) of a religious denomination (for example,
Baptist, Pentecostal, Catholic, etc.)?
___ Yes ___No
If yes, please describe the denomination.
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
109.
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AFFIRMATION
I, _______________________hereby declare under penalty of perjury that the foregoing
answers set forth in this Jury Questionnaire 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 in this Jury Questionnaire
myself.
Executed on this
Continuation of Answers:
Question No. ____, continued:
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