Response in Opposition by USA as to Eric Dean Sheppard — USA v. Sheppard (Dkt. 88, S.D. Fla.)

Summary

Document 88, a two-page United States' Response to Defendant's Motion for a Written Jury Questionnaire filed 09/18/2023 in the Southern District of Florida, Case No. 22-20290-CR-BLOOM(s), United States v. Eric Dean Sheppard. The government opposes the procedure in which jurors would come to the courthouse a day early to fill out the defense questionnaire so the parties can review the answers. It argues that jury duty is already a burden, particularly for the self employed, and says the case is not Enron and not a high profile one that needs extensive voir dire. It suggests the defense propose voir dire questions to the court or ask them during its allotted time, and Aimee C. Jimenez signs.

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Full text

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO.  22-20290-CR-BLOOM(s)      
 
UNITED STATES OF AMERICA 
 
vs. 
 
 
 
 
 
 
 
 
ERIC DEAN SHEPPARD, 
 
                
Defendant. 
__________________________________/ 
 
 
UNITED STATES’ RESPONSE TO DEFENDANT’S  
MOTION FOR A WRITTEN JURY QUESTIONNAIRE 
 
 
The United States of America, through the undersigned Assistant United States Attorney, 
files this response to the defendant’s motion for a written questionnaire in order to clarify the 
government’s position regarding the defendant’s motion. 
 
The government opposes the procedure the defendant is asking the Court to adopt for the  
jurors to answer the defendant’s proposed questionnaire.  Jury duty is a service that many people 
find to be a burden on their personal lives and their finances, particularly if they are self employed.  
The government does not believe that additional burdens should be placed on the jurors by 
requiring them to come to the courthouse a day ahead of the defendant’s proposed trial schedule 
and fill out the defense questionnaire so that the parties can have a full day to digest the jurors’ 
responses.   
 
This is not Enron; this is not a high profile case.  This is not a case that requires extensive 
voir dire that should begin a day ahead of the normal trial schedule.  The government believes the 
defendant can propose his voir dire questions to the Court, and if the questions are not asked by 
the Court, the defendant’s counsel can ask the jurors the questions they deem appropriate during 
Case 1:22-cr-20290-BB   Document 88   Entered on FLSD Docket 09/18/2023   Page 1 of 2

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the time allotted to them for voir dire.     
 
For these reasons, the government respectfully requests that the proposed voir dire 
procedure offered in the defendant’s motion for a written jury questionnaire be denied. 
 
 
 
 
 
Respectfully submitted, 
                                                 
 
MARKENZY LAPOINTE 
                                                 
 
UNITED STATES ATTORNEY 
 
                                          
 
By:    s/Aimee C. Jimenez            
                                                 
 
Aimee C. Jimenez 
                                                 
 
Assistant United States Attorney 
                                                 
 
Court No. A5500795 
                                                 
 
99 N.E. 4th Street 
                                                 
 
Miami, Florida 33132-2111 
                                                 
 
Tel: (305) 961-9028 
                                                 
 
Fax: (305) 530-7976 
                                                 
 
Email: aimee.jimenez@usdoj.gov 
 
 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that on September 18, 2023, I electronically filed the foregoing  
 
document with the Clerk of the Court using CM/ECF.  
 
s/Aimee Jimenez                           
Aimee C. Jimenez 
Assistant United States Attorney 
 
 
 
Case 1:22-cr-20290-BB   Document 88   Entered on FLSD Docket 09/18/2023   Page 2 of 2

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