Court filing
Proposed Voir Dire by Anuli Okeke — Proposed Voir Dire by Anuli Okeke — USA v. Okeke (Dkt. 34) (Dkt. 34, E.D.N.Y.)
Filed May 17, 2024 in Docket NYED 474435, the only filing from this case in the archive.
Record facts
| Court | U.S. District Court for the Eastern District of New York |
|---|---|
| Filed | 2024-05-17 |
U.S. District Court for the Eastern District of New York · No. 1:22-cr-00020-FB · Doc. 34 · 2024-05-17 · Docket on CourtListener
Full text
UNITED STATES DISTRICT COURT
SOUTHERN EASTERN OF NEW YORK
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UNITED STATES OF AMERICA
- v. –
ANULI OKEKE,
Defendant.
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22 Cr. 20 (FB)
DEFENDANT ANULI OKEKE’S
PROPOSED VOIR DIRE
Sanford N. Talkin
Noam B. Greenspan
Talkin, Muccigrosso & Roberts, LLP
40 Exchange Place, 18th Floor
New York, New York 10005
(212) 482-0007
Attorneys for Anuli Okeke
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PROPOSED EXAMINATION OF PROSPECTIVE JURORS
Defendant Anuli Okeke respectfully requests, pursuant to Rule 24(a) of the Federal Rules
of Criminal Procedure, that the Court include the following questions in its examination of
prospective jurors. The Court is requested to pursue more detailed questioning at the sidebar if a
prospective juror’s answer reveals that further inquiry is appropriate and, in such an instance, to
conclude with an inquiry as to whether the particular fact or circumstance would influence the
prospective juror in favor of or against either the Ms. Okeke or the government.
A. Preliminary Matters
1.
Anuli Okeke, the defendant in this case, denies all of the charges against
her and asserts her innocence. Under the law, the jury must presume she is innocent of all the
charges. It is the government’s burden to prove each charge, if it can, beyond a reasonable doubt,
and that burden never shifts to the defense.
2.
Ms. Okeke has no obligation to present any defense, call any witnesses,
offer any evidence, or testify. And if she does not testify, you cannot view her choice not to
testify as evidence of guilt.
3.
The charges against Ms. Okeke are listed in an Indictment. The Indictment
is not evidence of guilt, and you may not consider it as evidence of anything. The Indictment
merely serves to notify Ms. Okeke what the charges are against her and contains only unproven
allegations.
4.
You will hear a lot more about these charges in the coming days, but let me
provide you with a brief summary of the allegations in this case in order to help determine
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whether there is anything about the case that may make it difficult or inappropriate for you to
serve on the jury.
5.
In this case, the charges identified in the Indictment are: (i) a conspiracy to
commit wire and bank fraud; (ii) individual substantive counts of wire and bank fraud ; and (3) a
conspiracy to commit money laundering. You may not draw any conclusions about the guilt of
Ms. Okeke just because he has been indicted. The Indictment does not change in any way the
presumption of innocence.
6.
The Indictment alleges that the defendant obtained money by agreeing to
and in fact defrauding Banco Popular and the United States Small Business Administration in
relation to the Paycheck Protection Program (“PPP”) and the Economic Injury Disaster Loans that
were established as part of Coronavirus Aid, Relief and Economic Security (“Cares”) Act.
7.
For this alleged conduct, the defendant has been charged in the Indictment
with three separate charges, or “counts,” charging that the defendant violated the federal laws
that make it unlawful to conspire to commit wire and bank fraud, actually committed wire and
bank fraud and conspired to commit money laundering.
8.
Ms. Okeke maintains her innocence and has pleaded Not Guilty to the
charges. Ms. Okeke contends that she acted lawfully and in good faith at all times. It is the
government’s burden, as to every element of each count, to prove guilt, if it can, beyond a
reasonable doubt. If the government fails to do so, the jury must find Ms. Okeke not guilty.
9.
We are about to select from among you the jurors who will sit in this case.
Both sides are entitled to know something about the people who sit as jurors. Trial by jury is one
of our most treasured rights in the United States. Sitting on a jury is one of the highest forms of
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public service. Because of this, we all have an obligation to serve on juries, when called. The
law provides this procedure to ensure that both the defendant and the government receive the
fairest possible trial. For this reason, I am going to ask you certain questions about the case,
your background, important constitutional principles, and any experiences you may have had that
might affect your ability to serve as a juror in this case. We are not trying to find out if you are a
good juror or a bad juror, but whether you are the right juror for this particular case. Because
just as we have an obligation to serve jury duty, we also have that same obligation not to serve on
certain juries – and that could be because of your feelings, opinions, or even biases on different
issues. We all have life experiences, we all have biases – and it may be that this is not the right
case for you, but you’d be perfect on one hundred other juries. It is vital that you provide truthful
answers to these questions. They are not meant to embarrass you in any way, but only to elicit
the basic information necessary to permit the parties and the Court to make an informed choice
of jurors for the case. No one is going to be mad at you or judge you for having certain opinions.
10.
Were you able to understand what I just said? Do you have any difficulty
reading, speaking, or understanding English?
11.
Ther trial is scheduled to last about 3 weeks. Although we are selecting
the jury today, the trial will not begin until next Monday, June 10, 2024. Do you have any
immovable conflicts, such as scheduled medical procedures (surgeries, non-routine doctors’
appointments, etc.), family events (weddings, funerals, etc.), religious holiday obligations, final
exams, or childcare obligations?
B.
Case Specific Inquiry
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1.
Do any of you know anything about the facts of this case, other than what
I have told you? If yes. [If a prospective juror has heard of or otherwise is familiar with any
aspect of this case, the Parties respectfully ask that the Court question the prospective juror
outside the presence of the broader jury pool.]
a.
What do you know, or have you read/heard?
b.
From what source did you learn, hear or read about it?
c.
Based on what you heard or read, have you formed any opinions or views
one way or the other about Ms. Okeke’s innocence or guilt in this case?
2.
Have any of you heard, read, or seen anything that for any reason would
prevent you from rendering a fair and impartial judgment in this case?
3.
Let me now ask you a few questions about the general subject matter of
the case.
4.
The Indictment alleges crimes related to the administration of the CARES
Act and the Paycheck Protection Program (“PPP”) where the government provided businesses
with loans, repayment of which would be forgive under certain circumstances, in order to
support businesses negatively impacted by the coronavirus.
(a) Did you, a family member, or close friend apply for a PPP loan? If so, what
type of business was the loan requested for, was the loan actually received
and was repayment ultimately forgiven?
(b) Do any of you have feelings or impressions regarding the government
response to the coronavirus and the PPP program that would affect your
ability to be fair in this case or your ability to make an unbiased decision as to
whether the government has proven its case beyond a reasonable doubt?
(c) Do you have opinions about the CARES Act and PPP in general that could
affect your ability to be an impartial juror in this case? If so, please explain.
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(d) Do or did you, a family member, or close friend work at or for a bank
presently or in the past?
(e) Do any of you have opinions regarding the impact of the coronavirus on the
economy that could affect your ability to be an impartial juror in this case? If
so, please explain.
5.
How often do you conduct your banking by going to a bank branch ?
6.
How often do you conduct your banking remotely?
7.
Have you had any negative experience with a bank or bank employee that
would affect your ability to be fair and impartial in this case?
8.
Do you, a family member, or close friend now, or in the past, start or own
a business, practice, or firm?
C.
Knowledge of the Trial Participants
1.
Do you, a family member, or close friend now, or in the past, started or
owned a business, practice, or firm?
2.
Do any of you know, or have you had any dealings, directly or indirectly,
with Ms. Okeke, or with any of her relatives, friends or associates?
14.
To your knowledge, do any of your relatives, friends, associates, or
employers know the defendant?
15.
Ms. Okeke is represented by Sanford “Sam” Talkin and Noam Greenspan,
of the law firm Talkin, Muccigrosso & Roberts, LLP. If I could have the members of the defense
team please stand and face the venire.
a. Do any of you know these attorneys?
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b. Have you or your family members or close friends had any dealings either directly
or indirectly with either of these lawyers or the law firm Talkin, Muccigrosso &
Roberts, LLP?
16.
The Government is represented here, as in all cases where it is a party
before the Court, by the United States Attorney for the Eastern District of New York, who, for
purposes of the matter, is Breon Peace. Have you or your family members or close friends had
any dealings either directly or indirectly with Mr. Peace? The conduct of the trial will be in the
immediate charge of Assistant United States Attorneys Chand Edwards-Balfour Adam Amir
along with United States Department of Justice Trial Attorney Jennifer Bilinkas . If I could have
the members of the prosecution team please stand and face the venire. Do any of you know Mr.
Edwards-Balfour, Mr. Amir or Ms. Bilinkas? Have you or your family members or close friends
had any dealings either directly or indirectly with them? The Government attorneys will also be
assisted in the case by Special Agent Lauren Munoz of the Office of the Inspector General of for
the Board of Governors of the Federal Reserve System and the Bureau of Consumer Financial
Protection, and Wesley Roberts, paralegal specialists in the United States Attorney’s Office.
[Please ask Special Agent Munoz and Wesley Roberts to stand.] Have you or your family
members or close friends had any dealings either directly or indirectly with Special Agent Munoz
or Mr Roberts?
B.
Names and Places
17.
I will now read a list of names of individuals and businesses whose names
may be mentioned during the trial, or who may be witnesses in the case [To be provided in
advance of trial]:
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Are any of you familiar with any of these people, entities, or places apart from simply
being a customer of one of the entities?
C.
Relationship with Government and Others
18.
Do any of you know, or do, a family member or close fried have any
association – professional, business, or social, direct or indirect – with any member of the staff of
the United States Attorney’s Office for the Eastern District of New York, the United States
Department of Justice, the Federal Bureau of Investigation, the Office of the Inspector General of
for the Board of Governors of the Federal Reserve System, the Bureau of Consumer Financial
Protection or the United States Small Business Administration or the Federal Deposit Insurance
Company?
19.
Are you, or is any member of your family or a close friend, employed by
any law enforcement agency, whether federal, state, or local?
20.
Have you, or any member of your family or a close friend, ever been
employed by any law enforcement agency?
21.
Have you, either through any experience you have had or anything you
have seen or read, developed any bias, prejudice or other feelings for or against the United States
Attorney’s Office or any federal law enforcement agency.
22.
Have you, or has any member of your family or a close friend, either as an
individual or in the course of business, ever been a party to any legal action or dispute with the
United States, or with any of the officers, departments, agencies, or employees of the United
States?
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23.
Have you or any member of your family or any close friend ever had any
education or training, applied or worked for, or volunteered in, any area of criminal defense, such
as a public defender office, a law office, or a private investigation firm? If yes, please describe
the training, job and the type of office and, if other than yourself, state the person’s relationship
with you.
D.
Prior Experience with the Court System
24.
Are you, or any of your family members or close friends, attorneys or
employees of a law firm?
25.
For the next series of questions, the terms “governmental agency” and
“licensing authority” should be understood to include, among all other governmental agencies and
licensing authorities.
26.
Have any of you, or any of your relatives or close friends, ever been
involved or appeared as a witness in any investigation by a federal or state grand jury, or by a
legislative committee, governmental agency, or licensing authority?
27.
Have you, or any of your relatives or close friends, ever been questioned in
any matter by a federal, state, or local law enforcement agency?
28.
Have you, or any of your relatives or close friends, ever been interviewed
as a potential witness or a complainant in any federal, state, or local prosecution? Did you or they
ever serve as a witness in trial? What about in a civil case? If so, what was the case about?
29.
Are you, or any of your relatives or close friends, now under subpoena or,
to your knowledge, about to be subpoenaed, in any criminal case?
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30.
Have you, or have any of your relatives, associates or close friends, ever
been charged with a crime? What crime? [As to any prospective juror who answers
affirmatively, the Court is respectfully requested to inquire, at the bench, into the circumstances
of the charges.]
31.
Have you, or have any of your relatives, associates or close friends ever
been the subject of any investigation or accusation by any federal or state grand jury, or by any
legislative committee or other governmental agency, or any other federal, state, or local agency?
[As to any prospective juror who answers affirmatively, the Court is respectfully requested to
inquire, at the bench, into the circumstances of the investigation.]
32.
Have you, or any of your relatives or close friends, ever been a victim of a
crime, whether it was reported or not? [As to any prospective juror who answers affirmatively,
the Court is respectfully requested to inquire, at the bench, into the circumstances of each crime.]
If yes, what was the crime? Was anyone arrested? If so, what happened to the case? Is there
anything about that experience that would affect your ability to be fair and impartial in this case?
33.
Have you, or any member of your family or close friends, ever been
arrested, charged with, or convicted of a crime? [As to any prospective juror who answers
affirmatively, the Court is respectfully requested to inquire, at the bench, into the circumstances
of each crime]. Is there anything about that experience that would affect your ability to be fair and
impartial in this case?
34.
Is there anything about your experience with law enforcement that would
affect your ability to be fair and impartial in this case?
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35.
Have you, or any of your relatives or close friends, had any experience
with law enforcement that you think may affect your ability to render a fair verdict? [As to any
prospective juror who answers affirmatively, the Court is respectfully requested to inquire, at the
bench, into the circumstances of each incident and that prospective juror’s reaction to how he or
she was treated by the law enforcement agents.]
E.
Prior Jury Service
36.
Have you ever, at any time, served as a member of a grand jury, whether in
federal, state, county or city court? If so, when and where did you serve?
a. What type of case was it?
37.
Have you ever served as a juror in any court? If so, when, and in what
court did you serve, and was it a civil or criminal case? What was the nature of the case?
Without saying what it was, did the jury reach a verdict?
38.
Have you ever served as the foreperson on any jury or grand jury?
39.
Do you understand that the standard of proof in a criminal trial (such as
this one) is much, much higher than the standard of proof in a civil trial?
F.
Law Enforcement Witnesses
40.
The Government witnesses in this case may include law enforcement
officers. Would any of you be more likely to believe a witness merely because he or she is a
member of a law enforcement agency? Would any of you be less likely to believe a witness
merely because he or she is member of a law enforcement agency?
41.
Does anyone have any personal feelings or experiences concerning law
enforcement witnesses, who would in any way affect their ability to be fair and impartial in this
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case?
42.
Do you believe that if a lawyer for the government or a law enforcement
officer says that something is true or a fact, it must be true, or at least likely true?
43.
Do you believe that the government only charges an individual with a
crime if they are guilty?
44.
Have you, or any member of your family or close friends, ever been a
member of any group that lobbies or takes positions on law enforcement issues?
45.
Do you have any family or friends who work for any federal, state or local
law enforcement agency?
46.
Have you, or any member of your family or close friends, ever been
employed by any prosecutor’s office, whether local, state or federal?
47.
Do you have any family or friends who work for the United States
Attorney’s Office for the Eastern District of New York?
48.
Have you, or any member of your family or close friends, ever worked for
the United States government or for any of its offices, departments, or agencies?
49.
Do you have any family or friends who are judges, law clerks, court
attendants, court clerks, or any other type of court personnel?
50.
Do you think the fact that the federal government is a party here might
affect the way you would think about this case and your ability to be fair and impartial?
51.
Do you believe that when the U.S. government brings a white-collar
criminal case against someone, the government has always done a fair and thorough
investigation?
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52.
Have you, or any member of your family or close friends, ever been
involved in a lawsuit or dispute with the federal government or any federal agency?
53.
Have you, or any member of your family or close friends, been involved in
a lawsuit of any kind? If yes, please tell us briefly about the lawsuit.
G.
Presumption of Innocence
54.
As stated before, the Indictment in this case is not evidence or proof of
anything. It simply notifies Ms. Okeke with what she is charged. Even knowing that, do you feel
that because Ms. Okeke has been indicted and accused of a criminal offense that means she is
guilty?
55.
When it comes to a criminal case, a bedrock principle is the presumption of
innocence. Is there anything about the nature of the charges or Ms. Okeke herself that makes it
difficult for you to presume her to be innocent in this case? What are your thoughst about the fact
that you must presume her innocent as he sits here today? Can you do that?
56.
Do you think that because Ms. Okeke has been charged by the government
and is here on trial, she must have done something wrong or illegal? Do you think that just
because a person sits here today, accused of something, she’s automatically guilty or probably
guilty?
57.
Do you believe it is possible that the government could charge someone
with a serious offense and that person is Not Guilty? Do you believe completely innocent people
can be wrongly accused?
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H.
Judging the Credibility of Witnesses – Types of Witnesses
58.
If someone comes to court and takes an oath, will you automatically
believe that what a witness testifies to is true/fact?
59.
Are you open to the possibility that a witness could come into court and
lie?
60.
Do you feel comfortable judging whether a witness is telling the truth or a
lie, is mistaken or confused, or remembers things incorrectly?
I.
Buren of Proof
61.
Ms. Okeke is not required to disprove the case or present any evidence or
witnesses at all. The law states that it is the government’s job to prove the case, if it can, beyond
a reasonable doubt. This is called the burden of proof. Knowing this, will you still expect Ms.
Okeke to put on a case or call witnesses to testify?
62.
Do you think someone accused of a crime should have to prove they are
innocent?
63.
Will you hold the government to its burden?
64.
Under the law, if the defense chooses to put on a case, it does not alter the
government's burden of proof in any way. The burden to prove their case beyond a reasonable
doubt never shifts to Ms. Okeke. She does not assume a burden to prove her lack of guilt by
choosing to put on a case. Would you have any problem accepting and applying this rule of law?
J.
Beyond a Reasonable Doubt
65.
Before you could ever convict Ms. Okeke, not only must the government
prove its case, but it must prove it beyond and to the exclusion of every reasonable doubt. There
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is the highest level of proof in the law. Do you understand that proof “beyond a reasonable
doubt” is the highest burden that we have under the law – higher than “clear and convincing” and
higher than the civil level of “preponderance of the evidence?”
66.
Even though the law states that the government must prove its case against
Ms. Okeke beyond a reasonable doubt before you ever can find her guilty, at the end of the day, if
you think she probably did it, what will your verdict be?
67.
If at the end of this case, you have a gut feeling that the defendant may
have committed the crimes with which he is charged, but the government did not meet its burden
of proving the defendant’s guilt beyond a reasonable doubt, would you hesitate to find the
defendant Not Guilty? How many of you would follow your “gut” feeling as opposed to the law?
68.
Will you require the government to prove its case to the high level of
beyond a reasonable doubt before you can ever find Ms. Okeke guilty?
K.
Other Questions
69.
Do any of you have problems with your hearing or vision which would
prevent you from giving full attention to all of the evidence at this trial?
70.
Are any of you taking any medication, or do any of you have any medical
condition that would prevent you from giving full attention to all of the evidence at this trial?
Does it affect your ability to think or to reason or to remember? Do you take it regularly? How
long have you been taking it? Have you ever had any adverse reaction to it?
71.
Do you have any difficulty with listening, paying attention, reading printed
materials, deliberating or otherwise participating as a juror? Do you have any medical condition
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that would make it difficult or uncomfortable to sit for long periods of time without breaks or that
might interfere with your service in this case?
72.
Do any of you have any religious, philosophical or other beliefs that would
make you unable to render a guilty verdict for reasons unrelated to the law and the evidence?
L.
Function of the Court and Jury
73.
The function of the jury is to decide questions of fact. You are the sole
judge of the facts and nothing that the Court or the lawyers say or do may encroach in any way on
your role as the exclusive fact-finder. When it comes to the law, however, you are to take your
instructions from the Court, and you are bound by those instructions. You may not substitute
your own notions of what the law is, or what you think it should be. At the conclusion of the
case, your job will be to determine whether or not the defendant is guilty as charged in the
indictment. Do any of you have any bias or prejudice or belief that might prevent you from
accepting the instructions of law that I will give you in this case?
74.
Will each of you accept the proposition that the question of punishment is
for the Court alone to decide, and that the possible punishment must not enter into your
deliberations as to whether the defendant is guilty or not guilty?
75.
Will each of you accept the proposition of law that sympathy or empathy
must not enter into the deliberations of the jurors as to whether the defendant is guilty or not on
each count, and that only the evidence produced here in court may be used by you to answer the
question of guilt on each count?
76.
It is not a particularly pleasant duty to find another individual guilty of
committing a crime. Do any of you feel that even if the evidence established a defendant’s guilt
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beyond a reasonable doubt, you might not be able to render a guilty verdict for reasons unrelated
to the law and the evidence?
77.
If selected to participate as a juror, would you be able to reach a verdict
based solely on the facts and documents in evidence and the law as the Court will instruct you,
disregarding other ideas, notions, or beliefs about the law that you may have encountered
elsewhere?
M.
Other Biases
78.
In these questions, I have tried to direct your attention to possible reasons
why you might not be able to sit as a fair and impartial juror. Apart from any prior question, do
any of you have the slightest doubt in your mind, for any reason whatsoever, that you will be able
to serve conscientiously, fairly and impartially in this case, and to render a true and just verdict
without fear, favor, sympathy, bias, or prejudice – and according to the law as it will be explained
to you?
79.
Do you know of any reason, other than that which has already been
discussed, why you would be prejudiced for or against the United States or Ms. Okeke that you
have not been asked about?
N.
Juror’s Background
80.
The Parties respectfully request that the Court ask each juror to state the
following information:
a.
the juror’s name and age;
b.
the area in which the juror resides, how long they have lived there,
and any other areas in which the juror has resided during the last
10 years;
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c.
the members of the juror’s household;
d.
the juror’s educational background, including the highest degree
obtained;
e.
the juror’s occupation;
f.
the name and location of the juror’s employer;
g.
the same information concerning any other employment within the
last 10 years; if retired, the juror’s job before retirement.
h.
the same information with respect to the juror’s spouse and any
working children;
i.
whether the juror has served in the military;
j.
the names of any clubs or associations of which the juror is a
member;
k.
What is the juror’s main source of news – newspaper, television,
websites, or other sources? the names of any publications, print or
online (including blogs), to which the juror subscribes and/or
contributes;
l.
which newspapers and magazines the juror regularly reads; what if
any, online media the juror regularly reads; how many times a
week they read each source.
m.
which television programs the juror regularly watches;
n.
Does the juror read any finance-related news publications or listen
to any finance-related programs or podcasts? and
o.
the juror’s hobbies and leisure-time activities and organizations.
p.
what social media platforms does the juror use, if any?
O.
Requested Instruction Following Impaneling of the Jury
81.
From this point until the time when you retire to deliberate your verdict, it
is your duty not to discuss this case, and not to remain in the presence of other persons who may
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be discussing this case. The rule about not discussing the case with others includes discussions
even with members of your own family and your friends.
82.
If at any time during the course of this trial, any person attempts to talk to
you or to communicate with you about this case, either in or out of the courthouse, you should
immediately report such an attempt to me through my deputy clerk. In this regard, let me explain
to you that the attorneys and the defendants in a case are not supposed to talk to jurors, not even
to offer a friendly greeting. So if you happen to see any of them outside this courtroom, they will,
and should, ignore you. Please do not take offense. They will be acting properly and consistent
with my instructions to them by doing so.
Dated: New York, New York
May 17, 2024
Respectfully submitted,
Sanford Talkin
Sanford Talkin
Noam Greenspan
Noam Greenspan
Attorneys for defendant Anuli Okeke
Talkin, Muccigrosso & Roberts, LLP
40 Exchange Place, 18th Floor
New York, New Your 10005
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- 59569b144bcf2962fe67bcd40dbe1e1a7e83d6a223d9fe4a0814aed364da690e
- Original
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