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Home Court filings USA v. Thomas et al USA v. Thomas et al — Carla Jackson judgment, N.D. Ga. Proposed Voir Dire Questions as to Carla Jackson, John Gaines, Jerry Baptiste — USA v. Thomas et al. (Dkt. 797, N.D. Ga.)

Court filing

Proposed Voir Dire Questions as to Carla Jackson, John Gaines, Jerry Baptiste — USA v. Thomas et al. (Dkt. 797, N.D. Ga.)

Filed January 4, 2024 in USA v. Thomas et al.; one of 81 filings from this case.

Record facts

CourtU.S. District Court for the Northern District of Georgia
Filed2024-01-04

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00296-JPB-CMS · Doc. 797 · 2024-01-04 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
TELDRIN FOSTER, 
JOHN GAINES A/K/A  
   MARTY   GAINES, 
JERRY BAPTISTE, AND 
CARLA JACKSON 
 
 
Criminal Action No. 
1:20-CR-00296-JPB 
United States’ Proposed Voir Dire Questions 
The United States of America, by Ryan K. Buchanan, United States 
Attorney for the Northern District of Georgia, and Tal C. Chaiken and 
Samir Kaushal, Assistant United States Attorneys, and by Glenn S. Leon, 
Chief of the Fraud Section, and Siji Moore, Trial Attorney, respectfully files 
this list of proposed voir dire questions. The United States requests that 
each party be given 30 minutes to conduct voir dire. 
Case Related Conflicts 
1. This case involves allegations that the defendants engaged in 
conspiracies to fraudulently obtain Paycheck Protection Program funds. 
Do any of you have any personal knowledge of the facts of this case, or 
about the defendants, which has not come from what you have learned in 
court so far today?  
Case 1:20-cr-00296-JPB-CMS     Document 797     Filed 01/04/24     Page 1 of 5

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2. In this case, you will hear that the criminal investigation was 
conducted primarily by law enforcement officers with the FBI. Have you, 
your relatives, or your close friends had any experience with the FBI or 
any other agency of the United States government, which could cause 
unfair prejudice to the government?  
3. Some of the witnesses for the United States may be federal agents. 
For example, some witnesses may be from the FBI. Do you feel that you 
might tend to favor or disfavor these witnesses, or give them more or less 
credibility, just because they are federal agents?  
4. Do you otherwise have a strong bias for or against law enforcement? 
Would your belief affect your ability to serve as a fair and impartial juror? 
5. Have you, a relative, or a close friend ever sought or obtained a 
Paycheck Protection Program loan? Is there anything about that experience 
that might affect your ability to serve as a fair and impartial juror? 
General Questions 
6. Have any of you ever worked for a government agency, whether 
federal, state, or local, that you have not told us about already? 
7. Have any of you, your relatives, or your close friends ever had a 
negative experience with any federal, state, or local agency that could bias 
you against the prosecution? 
Case 1:20-cr-00296-JPB-CMS     Document 797     Filed 01/04/24     Page 2 of 5

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8. Have any of you, your relatives, or your close friends ever been 
involved in a lawsuit or any kind of litigation with the United States 
government? 
9.  Have any of you ever posted bond or acted as a surety for someone 
who was arrested or detained in a criminal case?  
a. If so, who was the person, and what was the crime charged?  
10. Have any of you, your relatives, or your close friends ever been 
convicted of a non-traffic criminal violation of either federal or state law? If 
so: (at bench or in camera, if juror prefers):  
a. Who was the family member or close friend?  
b. What type of crime was it?  
c. When did it occur?  
d. Did you testify?  
e. Was there anything that happened with the police, the 
prosecutor, the defense attorney, or the court that left you 
upset?  
f. Was there anything about this experience that would cause 
you to be unable to be fair and impartial in this trial if you are 
selected as a juror?  
Case 1:20-cr-00296-JPB-CMS     Document 797     Filed 01/04/24     Page 3 of 5

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11. Have any of you, or any member of your immediate family, ever 
received any legal training, practiced law, or worked in an attorney’s 
office?  
a. If so, please state who received the legal training, the type of 
training, the area of the law involved, and the employers.  
12. Have any of you, or any member of your immediate family, ever 
studied criminal justice or worked in the criminal justice system as a law 
enforcement officer, probation officer, parole officer, or in some other 
similar position? 
13. Your verdict must be based on the facts and evidence of the case. 
Your duty, as jurors, is to judge guilt or innocence based upon the 
evidence. It is the duty of the judge to instruct you on the law and to 
determine punishment if you vote guilty. The law does not permit you to 
consider emotion, sympathy, prejudice, vengeance, fear, or hostility. Do 
any of you believe that you would have difficulty following this rule? 
Case 1:20-cr-00296-JPB-CMS     Document 797     Filed 01/04/24     Page 4 of 5

600 U.S. Courthouse, 75 Ted Turner Drive S.W., Atlanta, GA 30303 
(404) 581-6000   fax (404) 581-6181 
5 
14. The law does not permit you to consider the issue of punishment 
because it has nothing to do with guilt or innocence. Would any of you 
vote “Not Guilty”—no matter what the evidence indicates—merely 
because the charged crimes may result in a prison sentence?  
15. Do any of you have any beliefs, whether moral, religious, 
philosophical, or otherwise, that would prevent you from being a fair and 
impartial juror, or that would make it difficult for you to sit in judgment of 
the defendant?  
Dated: January 4, 2024. 
 
RYAN K. BUCHANAN 
United States Attorney 
GLENN S. LEON 
Chief, Fraud Section 
 U.S. Department of Justice 
 
 
TAL C. CHAIKEN 
Assistant United States Attorney 
Georgia Bar No. 273949 
 
 
SIJI MOORE 
Trial Attorney, Fraud Section 
 U.S. Department of Justice 
 
SAMIR KAUSHAL 
Assistant United States Attorney 
Georgia Bar No. 935285 
 
 
600 U.S. Courthouse 
75 Ted Turner Drive SW 
Atlanta, GA 30303 
404-581-6000; Fax: 404-581-6181 
 
1400 New York Ave, NW 
Bond Building, 11th Floor 
Washington, DC 20005 
202-514-2000; Fax: 202-514-3708 
 
Case 1:20-cr-00296-JPB-CMS     Document 797     Filed 01/04/24     Page 5 of 5

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  1. Proposed Voir Dire Questions as to Carla Jackson — USA v. Thomas et al. (Dkt. 785, N.D. Ga.)same docket · 2024-01-02
  2. Motion in Limine with Brief In Supportby USA as to Carla Jackson, John Gaines — USA v. Thomas et al. (Dkt. 796, N.D. Ga.)same docket · 2024-01-04
  3. Joint Proposed Special Verdict Form as to Carla Jackson filed by USA — USA v. Thomas et al. (Dkt. 845, N.D. Ga.)same docket · 2024-01-23
  4. Motion in Limine to Prohibit the Government's Use of Evidence — USA v. Thomas et al. (Dkt. 897, N.D. Ga.)same docket · 2024-02-04
  5. Exhibit Response in Opposition by Teldrin Foster DOC no 914 — USA v. Thomas et al. (Dkt. 916-1, N.D. Ga.)same docket · 2024-02-11
  6. Notice of Filing United States Reply in Support of Motion — USA v. Thomas et al. (Dkt. 917, N.D. Ga.)same docket · 2024-02-11
  7. Jury Verdict as to Carla Jackson (5) Guilty on Count 46ss-47ss — USA v. Thomas et al. (Dkt. 928, N.D. Ga.)same docket · 2024-02-15
  8. Motion for Preliminary Order of Forfeiture for Forfeiture Money Judgement — USA v. Thomas et al. (Dkt. 976, N.D. Ga.)same docket · 2024-04-22
  9. Sentencing Memorandum as to Carla Jackson — USA v. Thomas et al. (Dkt. 987, N.D. Ga.)same case · 2024-05-03
  10. Exhibit SBA OIG Report June 2023 — USA v. Thomas et al. (Dkt. 987-2, N.D. Ga.)same case · 2024-05-03
  11. Sentencing Memorandum as to Carla Jackson filed by USA — USA v. Thomas et al. (Dkt. 994, N.D. Ga.)same case · 2024-05-08
  12. Order of Forfeiture for Forfeiture Money Judgment as to Carla Jackson (5) — USA v. Thomas et al. (Dkt. 1001, N.D. Ga.)same case · 2024-05-16
  13. Judgment and Commitment as to Carla Jackson (5), Counts 27-28, 46s-47s — USA v. Thomas et al. (Dkt. 1005, N.D. Ga.)same case · 2024-05-20
  14. TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 6,… — USA v. Thomas et al (Dkt. 1035)same case · 2024-06-17
  15. TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 7,… — USA v. Thomas et al (Dkt. 1036)same case · 2024-06-17
  16. TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 8,… — USA v. Thomas et al (Dkt. 1037)same case · 2024-06-17
  17. TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 9,… — USA v. Thomas et al (Dkt. 1038)same docket · 2024-06-17
  18. TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 12,… — USA v. Thomas et al (Dkt. 1039)same docket · 2024-06-17
  19. TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 13,… — USA v. Thomas et al (Dkt. 1040)same docket · 2024-06-17
  20. TRANSCRIPT of Proceedings as to Carla Jackson, Teldrin Foster held on February 14,… — USA v. Thomas et al (Dkt. 1041)same docket · 2024-06-17

Part of: USA v. Thomas et al — Carla Jackson judgment, N.D. Ga. · U.S. District Court for the Northern District of Georgia · Paycheck Protection Program (PPP) · COVID Economic Injury Disaster Loans (EIDL) · Criminal prosecutions · 2024 · Court filings

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