Proposed Voir Dire by USA as to Bernard Okojie — USA v. Okojie (Dkt. 83, S.D. Ga.)

Record facts

U.S. District Court for the Southern District of Georgia · No. 4:22-cr-00084-LGW-BWC · Doc. 83 · 2023-03-07 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT  
SOUTHERN DISTRICT OF GEORGIA 
SAVANNAH DIVISION 
 
UNITED STATES OF AMERICA 
) 
 
 
 
 
 
 
 
) 
v. 
 
 
 
 
 
) 
CASE NO: CR 422-84 
 
 
 
 
 
 
) 
 
 
 
 
 
 
BERNARD OKOJIE 
 
 
) 
 
 
UNITED STATES’ PROPOSED VOIR DIRE QUESTIONS 
 
The United States requests the following questions be asked of prospective 
members of the jury, in addition to those questions that are included on the standard 
jury questionnaire: 
I. 
Parties 
1. 
Does any juror know the defendant, Bernard Okojie, or any relative of 
the defendant? 
2. 
If so, how do you know that person?  For how long have you known him 
or her? 
3. 
Does any juror know the defendant’s attorney, John Ossick? 
4. 
Does anyone belong to any social, business, professional, fraternal, or 
religious organization or association with the following: 
a. the defendant? 
b. any members of his family? 
c. the defendant’s attorney? 
d. Any member of the defense attorney’s law practice? 
e. As to the defense counsel, his paralegal(s), investigator(s), or 
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support staff? 
f. If so, will your acquaintanceship with this person cause you to be 
unable to render a fair verdict in this case? 
5. 
Has any juror heard anything about this case? 
a. If you have, do you think that you can put that aside and 
determine the case solely on the evidence presented during the 
trial? 
6. 
Have you or any of your close friends or relatives had any personal 
dealings with the United States Attorney’s Office, the Small Business Administration 
(SBA) or the Federal Bureau of Investigation (FBI)? 
a. If yes, what kind of contact?  Have those dealings affected your 
ability to be fair and open-minded today? 
II. 
Experience with Financial Institutions, Lenders or Processors, the 
SBA, and the PPP and EIDL Programs 
 
7. 
The indictment in this case alleges that the defendant defrauded the 
Small Business Administration by obtaining loans issued during the COVID-19 
pandemic.  The loans in this case were issued through the Economic Injury Disaster 
Loan Program, commonly called “EIDL,” and the Paycheck Protection Program, 
commonly called “PPP.”  
a. Have you, a family member, or close friend ever received or applied 
for a loan under the PPP or EIDL program?  Please provide details.  
b. Do you have opinions regarding COVID relief funding, including the 
PPP and EIDL program, that would keep you from being fair and 
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impartial?  
c. Do you have any opinions regarding COVID-19 that would prevent 
you from being fair and impartial?   
8. 
Do you own a small business?  If so, approximately how many employees 
do you have?  
9. 
Have you, a family member, or a close friend ever worked for a bank, 
lender, loan processor, or other financial institution?  To your knowledge, did that 
involve making or processing PPP loans? 
10. 
Have you, a family member, or a close friend ever worked for the United 
States Small Business Association (“SBA”)? To your knowledge, did that work involve 
processing EIDL loans?  
11. 
You may hear testimony from representatives of the SBA. Have you had 
any experiences with the SBA that would make it difficult for you to evaluate that 
testimony fairly and impartially? 
12. 
Do you think you could be fair and impartial in weighing the evidence 
in a case in which the government is a victim? 
III. 
Experience with Fraud 
13. 
Have you, a family member, or a close friend ever been the victim of 
fraud? Please provide details. Is there anything about that experience that would 
interfere with your impartiality in this case? (If you would like, you may request we 
speak in the jury deliberation room to answer this question.) 
 
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IV. 
Experience with Law Enforcement 
14. 
Have you, a family member, or a close friend ever been arrested, 
charged, or convicted of any crime? If so, what was the crime? How was it resolved? 
Would that experience affect your ability to be a fair and impartial juror in this case? 
(If you would like, you may request we speak in the jury deliberation room to answer 
this question.) 
15. 
Have you, a family member, or a close friend ever had a negative or an 
unpleasant experience with law enforcement? If so, what happened? Would that 
experience affect your ability to be a fair and impartial juror in this case? 
16. 
Have you, or has anyone close to you, ever been falsely accused of 
committing a crime? 
17. 
Have you, or has anyone close to you, ever filed a lawsuit or complaint 
concerning the conduct of a law enforcement officer? 
18. 
You may hear testimony in this case from federal law enforcement 
agents. Is there anything that you have experienced, seen, heard, or read about that 
would prevent you from considering their testimony fairly and impartially? 
19. 
Do you have any opinions or feelings about the criminal justice system, 
such as judges, prosecutors, defense lawyers, and law enforcement officers, that 
would make it difficult for you to be a fair and impartial juror in this case? 
V. 
Knowledge of Potential Witnesses 
20. 
Do you know or are you familiar with any of the following individuals, 
who may be witnesses in this case? [The government respectfully requests the Court 
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read the government’s and defendant’s witness lists.] 
 
VI. 
Punishment and Sympathy 
21. 
Have you previously served in a jury for a criminal or civil case? What 
was the result?  Do you have any reservations about sitting in judgment of an accused 
person and returning a verdict in a criminal case? 
22. 
There are some people who, for moral, ethical, or religious reasons, 
believe that it is not proper or who would find it difficult to pass judgment on the 
conduct of others. Do any of you hold such a belief, or might you be affected by such 
beliefs? 
23. 
The potential punishment for the charged offenses is a matter that the 
jury should never consider in arriving at an impartial verdict. If you are selected as 
a juror, can you put aside any concerns you may have about potential punishment in 
arriving at a fair and impartial verdict in this case?  
24. 
If the Court instructs you that your verdict must not be based on 
sympathy, passion, or prejudice, but only on the evidence in this case and on the law 
as the Court instructs you on it, will you be able to follow that instruction? 
25. 
Knowing what you now know about this case, do you have any 
reservations about your ability to hear the evidence, deliberate with your fellow 
jurors, and return a fair and impartial verdict? 
 
 
 
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VII. 
Ability to Serve 
26. 
Do you have any difficulty understanding the English language or 
seeing or hearing things in the courtroom that could impair your ability to be a 
juror in this case? 
VIII. 
COVID-19 Considerations 
 
27. 
Do you have concerns about safely serving on a jury over the course of 
multiple days? 
Would those concerns affect your ability to be a fair and impartial 
juror in this case? 
(If you would like, you may request we speak in the jury 
deliberation room to answer this question.) 
28. 
Do you have safety concerns about deliberating with other jurors in the 
same room? Would those concerns affect your ability to be a fair and impartial juror 
in this case? (If you would like, you may request we speak in the jury deliberation 
room to answer this question.) 
 
 
 
 
 
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Respectfully submitted this 7th day of March 2023. 
 
 
 
 
 
 
 
JILL E. STEINBERG 
 
 
 
 
 
 
UNITED STATES ATTORNEY 
 
/s/ Matthew A. Josephson 
Matthew A. Josephson  
Assistant United States Attorney 
Georgia Bar No. 367216 
 
Email: Matthew.Josephson@usdoj.gov 
Post Office Box 8970  
Savannah, Georgia 31412  
T: (912) 652-4422  
 
/s/ Jennifer A. Stanley  
Jennifer A. Stanley 
Assistant United States Attorney 
Alabama Bar No. 8400E77T 
           Email: Jennifer.Stanley@usdoj.gov 
Post Office Box 2017 
Augusta, Georgia 30903 
T: (706) 826-4525 
 
 
 
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CERTIFICATE OF SERVICE 
This is to certify that I have on this day served all the parties in this case in 
accordance with the notice of electronic filing (ANEF@) that was generated as a result 
of electronic filing in this Court. 
This 7th day of March 2023. 
 
 
 
 
 
 
 
JILL E. STEINBERG 
  
 
 
 
 
 
UNITED STATES ATTORNEY 
 
/s/ Jennifer A. Stanley  
Jennifer A. Stanley 
Assistant United States Attorney 
Alabama Bar No. 8400E77T 
           Email: Jennifer.Stanley@usdoj.gov 
Post Office Box 2017 
Augusta, Georgia 30903 
T: (706) 826-4525 
 
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