Proposed Voir Dire Questions by USA as to Eric Dean Sheppard — USA v. Sheppard (Dkt. 92, S.D. Fla.)

Summary

The government's proposed voir dire questions in United States v. Eric Dean Sheppard, Case No. 22-20290-Cr-Bloom(s), U.S. District Court for the Southern District of Florida, entered 09/18/2023 as Document 92. Filed under Fed. R. Crim. P. 24(a), it asks the court to put these questions to the jury panel in addition to its standard questions. The questions cover prior involvement in lawsuits, views that would prevent judging another person or following the court's instructions, and experience with law enforcement and the IRS. A further set asks whether potential jurors or someone close to them own a business, applied for a PPP loan or an EIDL or another SBA loan, or had a negative experience with a bank.

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1 
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’ PROPOSED VOIR DIRE QUESTIONS 
 
 
Pursuant to Fed. R. Crim. P. 24(a), the United States respectfully requests that, in 
addition to the Court’s standard questions, the Court ask the following questions during voir dire 
of the jury panel.  The United States further requests that the parties be allowed to propose 
additional voir dire questions as may become appropriate during the examination of potential 
jurors.   
1.  GENERAL BACKGROUND 
a. Have you or someone close to you been involved in a lawsuit or court proceeding? 
i. What type of case was it? 
ii. Were you, or someone close to you, a party in the case, or a witness? 
iii. Is your impression that the proceeding was fair? 
iv. What is your impression of how you or someone close to you was treated? 
b. Do you feel that you could not judge another person for a criminal act, whether on 
religious, moral, personal or any other ground? 
Case 1:22-cr-20290-BB   Document 92   Entered on FLSD Docket 09/18/2023   Page 1 of 3

 
 
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c. Do you have any views about law or procedure that would make you unable to 
follow the Court’s instructions on the law in this case? 
2. EXPERIENCE WITH LAW ENFORCEMENT 
a. Have you or someone close to you had any experience with law enforcement? 
i. Was it local law enforcement, like a police officer, or was it federal law 
enforcement, like the FBI? 
ii. What is your impression of how you or the person close to you was 
treated? 
b. Other than filing taxes, have you or someone close to you had any experience with 
the Internal Revenue Service (IRS)? 
i. What happened? 
ii. What is your impression of how you or the person close to you was 
treated? 
3. EXPERIENCE WITH BUSINESS, BANKS, LOANS, AND THE SBA 
a. Do you or someone close to you own a business? 
i. What type of business is it? 
ii. Does it have employees? 
iii. How many? 
b. Have you or someone close to you applied for a Paycheck Protection Program 
(PPP) loan or an Economic Injury Disaster Loan (EIDL)? 
i. If so, were the loans received, and what were the amounts of the loans? 
ii. What is your impression of the experience with the application and the 
loan? 
Case 1:22-cr-20290-BB   Document 92   Entered on FLSD Docket 09/18/2023   Page 2 of 3

 
 
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c. Have you or someone close to you applied for any other type of loan through the 
government, including through the Small Business Administration (SBA)? 
i. What type of loan was it? 
ii. What is your impression of the experience with the application and the 
loan? 
d. Have you or someone close to you had a negative experience with a bank? 
i. What happened? 
ii. Would your feelings about that experience affect your ability to be fair in 
this case? 
Respectfully submitted, 
 
    
MARKENZY LAPOINTE 
  
 
UNITED STATES ATTORNEY 
 
 
 
 
 
 
 
By:     s/ Ana Maria Martinez               
 
 
 
 
 
 
ANA MARIA MARTINEZ 
ASSISTANT U.S. ATTORNEY 
 
Florida Bar No.0735167 
 
 
 
 
 
 
99 N.E. 4th Street 
Miami, FL 33132 
Phone: (305) 961-9431   
Fax: (305) 536-5321   
Email: Ana.Maria.Martinez@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.  I also certify that the foregoing document 
is being served this day on all counsel of record via Notices of Electronic Filing generated by 
CM/ECF.   
 
 
s/Ana Maria Martinez                        
Ana Maria Martinez        
Assistant United States Attorney 
Case 1:22-cr-20290-BB   Document 92   Entered on FLSD Docket 09/18/2023   Page 3 of 3

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