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Home Court filings Shibley United States v. Eric Shibley — W.D. Wash., No. CR20-0174-JCC Information — United States v. Shibley (Dkt. 100-1, W.D. Wash. No. 2:20-cr-00174)

Court filing

Information — United States v. Shibley (Dkt. 100-1, W.D. Wash. No. 2:20-cr-00174)

Filed November 8, 2021 in Shibley; one of 140 filings from this case.

Record facts

CourtU.S. District Court for the Western District of Washington
Filed2021-11-08

U.S. District Court for the Western District of Washington · No. 2:20-cr-00174-JCC · Doc. 100-1 · 2021-11-08 · Docket on CourtListener

Full text

JURY QUESTIONNAIRE – UNITED STATES V. ERIC SHIBLEY 
 
This questionnaire has been prepared to assist the Court and the parties selecting the jury 
in this case.  Please answer each question completely and accurately.  Your complete written 
answers will save time for the judge, the lawyers, and for you.  Your answers will have the effect 
of a statement given to the Court under oath. 
 
 
Portions of this questionnaire inquire about knowledge you may have about the case or 
about certain government programs relevant to the case.  Please do not do anything to learn, or 
learn more, about the case or the programs, including reading news reports or anything on the 
internet.  It is important that you do not expose yourself to additional information that you 
impact your ability to be a fair and impartial juror.   
 
For some of the questions, follow up questions by the Court or the attorneys may be 
necessary.  If there is any question that you would rather not discuss publicly, or would only 
want to discuss further in private, please place a (*) by that question and/or answer.  If it is 
necessary to discuss that matter further with you, it will not be done in front of other jurors. 
 
Please complete this questionnaire by yourself and do not consult with anyone else, or 
discuss the questions or your answers with anyone. 
 
 
 
__________________________________ 
Honorable John C. Coughenour 
United States District Court Judge 
 
 
Case 2:20-cr-00174-JCC     Document 100-1     Filed 11/08/21     Page 1 of 7

Juror No:____________ 
 
PLEASE STATE: 
 
1. Your name: (Please print): _________________________________________ 
 
BACKGROUND  
2. 
The case is titled United States v. Eric Shibley, and it involves allegations of false 
applications for PPP and EIDL loans.  Have you heard anything about this case? 
 
If yes, what have you heard? 
 
 
   
3. 
Do you know the defendant, Eric Shibley? 
 
4. 
Do you know the lawyers for the parties: Laura Connelly, Brian Werner, or 
Michael Nance? 
 
5. 
Do you know anyone who works at the United States Attorney’s Office or for the 
Department of Justice?  Who? 
 
 
6. 
Do you know anyone who is a defense attorney or works in criminal defense?  If 
so, who? 
 
7. 
Do you know the judge, the Honorable John C. Coughenour?   
 
8. 
Do you know anyone that works for the United States District Court?  Who? 
 
 
 
Case 2:20-cr-00174-JCC     Document 100-1     Filed 11/08/21     Page 2 of 7

9. 
Do you know any of the following potential witnesses? 
 
Kandace A. Zelaya 
 
 
 
 
Kathleen Littwin 
Mitchell Mondala 
 
 
 
 
Jeanne McDermott 
Brittney Beard 
 
 
 
 
Ramon Hernandez 
Geoff Hiller   
 
 
 
 
Cynde Cole  
John Mosier   
 
 
 
 
David Haagsma  
Justin Masterman  
 
 
 
 
Adam Seery 
Phil Watkins  
 
 
 
 
Lisa Velotta 
Mario Davis  
 
 
 
 
Michael Petron 
David Madrid  
 
 
 
 
Special Agent Kathleen Moran 
James Burnell 
 
10.   Have you served on a criminal or civil jury? 
 
a. If yes, were you able to reach a verdict? 
 
b. Anything about that experience that would prevent you from serving fairly an 
impartially on this jury? 
 
11. 
Have you ever received any training or work experience the following areas? 
____  Accounting/Bookkeeping  
 
____  Law 
____  Criminal Justice 
 
 
 
____  Medicine 
____  Construction 
  
 
 
____  Taxation 
If yes, please explain:   
 
 
12. 
Have you, any member of your family, or a close personal friend ever been the 
victim of a crime?   
a. If so, what type of crime?   
 
Case 2:20-cr-00174-JCC     Document 100-1     Filed 11/08/21     Page 3 of 7

13. 
Have you, or has any member of your family or a close friend, ever been 
employed by any law enforcement agency?  Please describe. 
 
 
 
14. 
Have you, any member of your family, or a close personal friend, ever been 
charged with a criminal offense, other than a minor traffic violation?  
a. If so, please describe the circumstances. 
 
 
b. Is there anything about this experience that would prevent you from being a 
fair and impartial juror in this case? 
 
 
15. 
Have you, any member of your immediate family, or a close personal friend, ever 
had a bad or unpleasant experience with a law enforcement officer or agency? 
a. If so, please describe that experience. 
 
b. Is there anything about that experience that would prevent you from sitting as 
a fair and impartial juror in this case? 
 
 
16. 
Do you have any feelings regarding the criminal justice system that might affect 
your ability to consider the evidence in this case fairly and impartially?  Please describe. 
 
FURTHER QUESTIONS 
17. 
Have you, or a family member applied for a loan pursuant to the Paycheck 
Protection Program (PPP)? 
 
 
18. 
Have you, or a family member applied for a loan pursuant with the Small 
Business Administration (SBA)?  If yes, please describe. 
Case 2:20-cr-00174-JCC     Document 100-1     Filed 11/08/21     Page 4 of 7

19. 
Do you know anyone that has applied for a PPP loan or an SBA loan?  If yes, 
please describe. 
 
 
20. 
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 SBA?   
 
 
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 FBI?  Or any other law 
enforcement agency?   
 
 
22. 
Have you or a family member ever worked for a bank, lender, loan processor, or 
other financial institution?  If yes, please describe the relationship and the position. 
 
 
 
23. 
Do you think you could be fair and impartial in weighing the evidence in a case in 
which a victim is a bank or other financial institution?  
 
 
24. 
Have you, a family member, or a close friend ever worked for the SBA? 
 
 
 
25. 
Have you or a family member ever worked for the government?  If yes, please 
describe the agency or branch of the government. 
 
 
 
Case 2:20-cr-00174-JCC     Document 100-1     Filed 11/08/21     Page 5 of 7

26. 
Do you think you could be fair and impartial in weighing the evidence in a case in 
which the government is a victim? 
 
27. 
In this case, the Defendant is accused of the crimes of wire fraud, bank fraud, and 
money laundering.  Is there anything about the nature of the charges that causes you to believe 
that you cannot sit as a fair and impartial juror in this case? 
 
 
28. 
Have you been a victim of or otherwise affected by what you believe to be fraud?  
If yes, please describe. 
 
 
 
29. 
Will you follow the instructions of law that the Court will give you at the close of 
the case regardless of whether you agree with the instructions or not? 
 
 
30. 
Would you disobey the judge’s instructions on the law simply because they are 
different from your own understanding of what the law is or should be? 
 
 
31. 
Do you have any philosophical or religious beliefs that would prevent you from 
judging the evidence and deciding a person’s guilt or innocence?  If yes, please describe. 
 
 
OTHER CONSIDERATIONS 
32. 
Do you have any concerns or issues with following the directions of the Court as 
it relates to masking, social distancing, and other COVID-19 protocols?  Please describe. 
 
 
33. 
Do you have concerns about safely serving on a jury over the course of multiple 
days?  
Case 2:20-cr-00174-JCC     Document 100-1     Filed 11/08/21     Page 6 of 7

a. If so, what are those concerns?   
 
 
b. Would those concerns affect your ability to be a fair and impartial juror in this 
case? 
 
34. 
Are there any deadlines, family issues, or personal health issues or concerns that 
would make it difficult for you to concentrate on the proceedings in court or otherwise difficult 
for you to sit as a juror?  Please describe. 
 
 
 
 
 
I have answered the above questions completely and truthfully. 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
Signature of Juror 
 
 
 
 
Date 
 
 
Case 2:20-cr-00174-JCC     Document 100-1     Filed 11/08/21     Page 7 of 7

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