Proposed Voir Dire by USA as to Te Dora Brown, Christopher Scott — USA v. Brown, et al. (Dkt. 133, N.D. Ill.)

Record facts

U.S. District Court for the Northern District of Illinois · No. 1:23-cr-00097 · Doc. 133 · 2026-05-06 · Docket on CourtListener

Full text

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UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF ILLINOIS 
EASTERN DIVISION 
 
UNITED STATES OF AMERICA 
 
   v. 
 
TE DORA BROWN 
 
No. 23 CR 97 
 
Honorable Elaine E. Bucklo 
 
THE GOVERNMENT’S PROPOSED VOIR DIRE QUESTIONS 
 
The United States of America, through its attorney, ANDREW S. BOUTROS, 
United States Attorney for the Northern District of Illinois, respectfully proposes the 
Court ask the following questions to all potential jurors, in addition to the Court’s set 
of general voir dire questions: 
1. 
Do you have any problem with your hearing, vision, or health that would 
make it difficult for you to serve as a juror?  
2. 
Do you have difficulty reading, speaking, or understanding English? 
3. 
Do you hold any religious, philosophical, moral, or other beliefs that 
would prevent you from returning a verdict in this case? 
4. 
This case involves an investigation by the United States Secret Service 
and the United States Small Business Administration.  Have you, a family member, 
or a close friend had any experiences or dealings with the United States Secret 
Service, the United States Small Business Administration, the federal government, 
or any law enforcement entity that might affect your ability to evaluate the evidence, 
to deliberate with the jury, or to return a verdict in this case?  
Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 1 of 4 PageID #:542

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5. 
Have you, a family member, or a close friend ever been arrested for, 
charged with, or convicted of any criminal offense other than a minor traffic violation?  
If yes, please indicate the nature of the offense; the law enforcement organization 
responsible for the arrest; the prosecutor’s office responsible for pursuing the charges; 
what happened in the case; and whether anything about that experience might affect 
your ability to evaluate the evidence, to deliberate with the jury, or to return a verdict 
in this case. 
6. 
Have you, a member of your family, or a close friend, ever been the 
victim of a crime? If so, please indicate the victim’s relationship to you; the nature of 
the offense; whether charges were brought against the offender; the disposition of 
those charges; and whether anything about that experience might affect your ability 
to evaluate the evidence, to deliberate with the jury, or to return a verdict in this 
case.  
7. 
Have you ever worked in the criminal justice system? If yes, please 
explain the circumstances. 
8. 
Do you have any close friends or relatives who are prosecutors or 
criminal defense attorneys? Is there anything about your relationships with them 
that would prevent you from evaluating the evidence, deliberating with the jury, or 
returning a verdict in this case? 
9. 
Defendant in this case is charged with wire fraud. She has pleaded not 
guilty to these charges. Is there anything about the nature of these charges that 
Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 2 of 4 PageID #:543

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might affect your ability to evaluate the evidence, to deliberate with the jury, or to 
return a verdict in this case? 
10. 
At various times during the case, the Court will instruct you about the 
applicable law. It is your obligation to follow the Court's instructions about the law, 
whether you agree with the law or not. If you were to find that you disagreed with 
the law as given to you by the Court, would you still be able to follow that law and 
reach a verdict by applying that law to the evidence in this case? 
11. 
What podcasts and/or radio programs you listen to regularly? 
12. 
What television shows do you watch regularly? 
13. 
Are there any other facts or circumstances that you believe the Court or 
the parties should know about concerning your ability to serve as a juror in this case? 
 
 
Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 3 of 4 PageID #:544

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To the Court’s general voir dire question regarding prior jury service, the 
government proposes the following additions: 
14. 
If you have previously served on a jury, please let us know the following: 
(a) whether the case was in federal court or state court; (b) whether it was a criminal 
case or civil case; (c) without disclosing to us what the verdict was, whether the jury 
was able to reach a verdict in the case; (d) whether you were the foreperson; and 
(e) whether your experience being on a jury left you with an impression of the legal 
system, judges, or attorneys—positive or negative—that might affect your ability to 
evaluate the evidence, to deliberate with the jury, or to return a verdict in this case. 
 
Respectfully submitted, 
 
ANDREW S. BOUTROS 
United States Attorney 
 
 
 
 
 
 
By: 
/s/ Mary Katherine McClelland  
 
MARY KATHERINE McCLELLAND 
 
 
 
 
 
 
QUINN FORD 
Assistant United States Attorneys 
219 South Dearborn Street, 5th Floor 
Chicago, Illinois 60604 
(312) 353-5300 
Dated: May 6, 2026 
 
Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 4 of 4 PageID #:545

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