Defendant's Proposed Voir Dire Questions — United States v. Abdulkadir Nur Salah (D. Minn., Doc. 421)

Summary

Defendant's Proposed Voir Dire Questions, filed 01/10/25 as Doc. 421 in United States v. Abdulkadir Nur Salah (4), Case No. 22-CR-223(4)(NEB/DTS), in the U.S. District Court for the District of Minnesota. Salah proposes questions for the court to ask prospective jurors, numbered 1 through 86. The sections cover personal background, prior legal experience, criminal justice experience, race, ethnicity and explicit and implicit bias, and following instructions and presumptions. The bias questions ask about contact with people from East Africa, particularly Somalia, and about first-generation immigrants. The list ends with a final question asking whether there is anything else that could affect a juror's ability to be impartial. The filing is dated January 10, 2025.

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“Defendant's Proposed Voir Dire Questions — United States v. Abdulkadir Nur Salah (D. Minn., Doc. 421).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-bock-et-al-feeding-our-future-dkt-421-d-m-73a9e68836/, SHA-256 25b3c2ef76f5def602caa3f9abca6aeb01011598d0ebd39af17f1eaa765ea8c5.

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CASE 0:22-cr-00223-NEB-DTS Doc. 421 Filed 01/10/25 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MINNESOTA

UNITED STATES OF AMERICA, Case No. 22-CR-223(4)(NEB/DTS)

Plaintiff,

v. DEFENDANT’S PROPOSED VOIR
DIRE QUESTIONS
4. ABDULKADIR NUR SALAH,

Defendant.

The defendant, Abdulkadir Nur Salah respectfully proposes the following

questions for the Court’s voir dire:

PERSONAL BACKGROUND

1. What is your name and address? How long have you lived there?

2. What other states or countries have you lived in during the last 10 years? For how

long?

3. Are you single, partnered, married, or divorced?

4. How old are you?

5. What race/ethnicity best describes you?

6. Have you ever served in the military? Please describe.

7. Describe your educational background, including the last grade or level of education

you completed, the name of any vocational schools or colleges attended, and your

major areas of study.

8. Are you currently employed? If so, what is your occupation?
CASE 0:22-cr-00223-NEB-DTS Doc. 421 Filed 01/10/25 Page 2 of 11

9. Who is your employer and what type of company or organization is it? Where is your

employer located? How long have you worked for this employer? What are your title

and job responsibilities?

10. If you are unemployed, retired, disabled, a full-time homemaker, or a student, what

type of work did you do most recently, including volunteer work? When were you last

employed, how long did you work there, and who was your employer?

11. For any job you hold or have held, including volunteer work, did your job require you

to manage other people?

12. Do you have any children? If so, what is the age, gender, level of education, and

occupation (if employed) of your children?

13. Does anyone else live with you, such as a spouse, domestic partner, or children?

14. What are the ages, levels of education, and occupations of those who live with you? If

employed, who is their employer?

15. Have you ever worked with government or other social services programs, as a job,

volunteer, or in any other capacity? Please explain.

16. Have you, or anyone close to you, ever been elected, appointed, or served on a

corporate or nonprofit board or government office, committee, advisory board, or

commission? Please describe.

17. What organizations do you belong to, including veteran’s groups, service clubs,

unions, volunteer groups, religious organizations, church or temple, neighborhood

organizations, educational organizations, and political organizations?

18. What are your hobbies and spare time activities?

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19. Would people describe you as a person who typically makes decisions using emotion,

gut, and intuition? Or typically analysis, calculation, and methodology? Please

describe.

20. Did you know any of your fellow jurors prior to meeting them here today?

21. Do you have any mental or physical condition which would make it difficult for you

to sit as a juror?

22. Are you dealing with any pressing matters in your life such as the death or sickness of

a loved one that would make it difficult for you to sit as a juror?

23. Is there anything about the anticipated length or anticipated daily schedule of this trial

that serving as a juror would create an undue hardship in your personal, work, or

family life? If yes, please explain.

24. Do you have any religious beliefs that would prevent you from sitting as a juror in

judgement of another person?

PRIOR LEGAL EXPERIENCE

25. Have you ever served on a jury, including a grand jury? If so, when, and what court?

Did you reach a verdict? Was it a criminal or civil case? Were you ever the

foreperson?

26. Was there anything about your previous experience that would lead you to feel that

you may have some feelings either for or against the prosecution or defense?

27. Have you ever been a witness in court or in a deposition? If yes, please explain.

28. Have you ever sued anyone or been sued? If yes, please explain.

29. Have you ever called the police or reported a crime? If yes, please explain.

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30. Do you have any legal training, or have you taken any law courses?

31. Have you, or has anyone close to you, ever been employed in any of the following

areas: (a) federal, state, or local government, (b) law or the courts, or (c) law

enforcement? If yes, please explain.

CRIMINAL JUSTICE EXPERIENCE

32. Have you, or has anyone close to you, ever had any previous contacts with the

criminal justice system, either as a victim of a crime, a person accused of a crime, or a

witness to a crime? Please describe this experience and how you believe it impacts

your view of the criminal justice system or sitting as a juror.

33. Do you know any police officers or other people who work in law enforcement? If so,

please tell us how you know them and how frequently you are in contact with them.

34. Do you have any opinions about prosecutors or defense attorneys that may affect you

in deciding this case?

35. Do you believe it is proper for the government to provide incentives for a witness to

testify, including the incentive of a lesser prison term, conditioned on the testimony

being favorable to the prosecution?

36. Would you tend to disbelieve the testimony of a witness who has been previously

convicted of a crime? Please explain.

37. Do you believe our criminal justice system works properly and fairly for all people?

What is your opinion on the criminal justice system?

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RACE, ETHNICITY, AND EXPLICIT AND IMPLICIT BIAS

38. Have your personal, professional, social, religious, educational, or other activities

brought you into contact with people whose backgrounds are in East Africa,

particularly Somalia? Please describe.

39. Do you work with any people from Somalia or of East African decent?

40. Do you have any family or close friends who are from Somalia or of East African

decent?

41. Are you, or is anyone close to you a first-generation immigrant?

42. Do you work with any person who is a first-generation immigrant?

43. Have you or a close associate of yours engaged in any business activities with an East

African business or person?

44. We all have feelings, assumptions, perceptions, fears an stereotypes about others.

Some biases we are aware of and others we might not be aware of, these are called

“implicit or unconscious bias.” No matter how unbiased we think we are; our brains

are hardwired to make unconscious decisions. Bias can affect our thoughts, how we

remember what we see and hear, whom we believe or disbelieve, and how we make

important decisions. Two common unconscious biases are people from another race

or ethnicity than ours and people who were born in another Country.

• If selected as a juror, would you feel comfortable committing yourself to

thinking about why you are making the decision you are and examining it

for bias?

5
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• Because people involved in this case are from different racial and ethnic

backgrounds than yourself can you commit yourself to carefully evaluate

the evidence and resist any urge to reach a verdict influenced by a hidden or

unconscious bias?

45. Do you have any feelings or beliefs about any particular race that would prevent you

from being unbiased about a person of any race?

46. Do you have any feelings or beliefs about immigrants that would prevent you from

being completely unbiased about a person who is an immigrant?

47. Do you have any feelings or beliefs about any religion, or about people who have

different religious beliefs than your own, that would prevent you from being

completely unbiased about a person with any particular religious beliefs?

48. Do you have feelings or beliefs about gender that would prevent you from being

unbiased against a person of any gender?

CASE SPECIFIC QUESTIONS

49. Have you, or anyone close to you, ever held a job in agriculture, food sales,

restaurants, institutional meal planning, or government programs in any of these

areas? Please describe.

50. Have you ever worked with government or other social services programs, as a job,

volunteer, or in any other capacity? Please explain.

51. Have you ever worked with or had exposure to the United States Department of

Agriculture (USDA), the Minnesota Department of Education (MDE) or their

programs, as a job, volunteer, or in any other capacity? Please explain.

6
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52. Have you ever heard of or ever been in contact with the following companies?

Feeding our Futures, Partners in Nutrition, Safari Restaurant, Cosmopolitan Business

Solutions, Cosmopolitan Business Properties, Bet on Better Future, Total Financial

Solutions? If so, how?

53. Have you, or anyone else you know had prior contact with the defendants, defense

attorneys, prosecutors, judge, or court staff in this case? [Names of parties, lawyers,

case agents, and witnesses].

54. This case concerns allegations of fraud. Have you or someone you know ever been

defrauded, regardless of whether the fraud was ever reported or prosecuted? Please

explain.

55. Are you more likely to treat the testimony of law enforcement officers with more

weight, less weight, or the same as other witnesses? If so, why?

56. Several witnesses in this trial are likely to be law enforcement officers or criminal

investigative agents of the United States. Do you believe that a law enforcement

officer is more likely to tell the truth than other people?

57. Recognizing the Defendants in a criminal case do not need to call any witnesses at all,

and the burden of proof always remains on the government, do you believe you would

be more likely to trust the testimony of a witness depending on which side called the

witness to testify, either the government or by a defendant?

58. Have you or has anyone close to you ever received any food or other benefit from a

Federal Child Nutrition Program, including the Summer Food Service Program or the

7
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Child and Adult Care Food Program, or any other state or federal program involving

the distribution of food? If so, please tell us about that.

59. This case involves allegations of fraud relating to Federal Nutrition Programs that are

designed to help feed children and certain adults. Is there anything about the fact that

this case involves allegations regarding the feeding of children that would impact your

ability to be fair to both sides and objectively consider the evidence presented? Please

explain.

60. Are you familiar with the area of Minneapolis around the intersection of East Lake

Street and 4th Avenue South, or the areas often referred to as the Phillips, Central, and

Powderhorn neighborhoods of Minneapolis? If so, how often do you find yourself in

these areas of Minneapolis and why do you tend to go to these locations?

MEDIA EXPOSURE

61. What is your primary source of news?

62. How often do you read a hard copy or online version of a newspaper?

63. What newspapers do you regularly read?

64. What podcasts or radio do you regularly listen to?

65. How often do you listen to local news on the radio or watch local news on television

or online?

66. Which local radio or television news station do you listen to or watch most?

67. What social media platforms, such as Facebook, Twitter/X, Instagram, or TikTok, do

you use regularly, if any?

68. How often do you see local news or news related updates on those social media sites?

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69. What have you heard about this case before today? If so, from what source and what

you have heard about this case?

70. Have you heard or read anything about an entity called Feeding Our Future? If so,

what have you heard?

71. What is the first thing that comes to mind when you heard the name “Feeding Our

Future?” Why do you feel that way?

72. What do you know about this case from media reports? It is important for the parties

to know all of the details you remember about these events, the case, Feeding our

Future, and Defendants Aimee Bock, Salim Said, Abdulkadir Salah, or Abdi Nur

Salah. Please take your time to search your memory and provide a full account of

what you recall from what you have heard or seen in the media. This will help to

shorten the jury selection process.

73. Have you watched any news broadcast either on television or the internet that

discussed Feeding our Future, any of the Defendants, or any of the events related to

this case?

74. Have you read any news articles, either in print or on the internet, that discussed

Feeding our Future, any of the Defendants, or any of the events related to this case?

75. From what you have seen, read, or heard, what are your general impressions of

Feeding our Future?

• Why do you feel that way?

76. From what you have seen, read, or heard, what are your general impressions of

Defendants Aimee Bock, Salim Said, Abdulkadir Salah, or Abdi Nur Salah?

9
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• Why do you feel that way?

77. From what you have seen, read, or heard, what are your general impressions of the

Minnesota Department of Education?

• Why do you feel that way?

78. From what you have seen, read, or heard, what are your general impressions of any

investigation conducted by either the United States Attorney’s Office, the Minnesota

Attorney General’s Office, or the Minnesota Department of Education related to

Feeding our Future, any of the Defendants, or any of the events related to this case?

• Why do you feel that way?

79. Have you ever talked about Feeding our Future, any of the Defendants, or any of the

events related to this case with any of your family, friends, or coworkers, or discussed

them online, for example, on social media?

• What opinions did you express during those conversations?

FOLLOWING INSTRUCTIONS AND PRESUMPTIONS

80. The court will instruct you that the Indictment returned by the grand jury is the formal

document by which the government starts its case against a defendant. The Indictment

is not evidence against a defendant and does not create an inference of guilt. Are you

able to accept the law that the Indictment is merely an accusation, does not change the

presumption that the Defendants are innocent, and that the Indictment is is not

evidence against a defendant?

10
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81. The Court will instruct you that a person who has been charged with a crime is

presumed innocent. Are you able to accept the law that the defendants in this case are

presumed innocent of the charges in the indictment?

82. Do you have any negative views about any of the defendants because they have been

accused of breaking the law?

83. Do you believe that the fact that the defendants have been accused of crimes makes it

more likely that they are guilty of those crimes?

84. As you sit here today, do you have any opinions about this case or what the results in

this case should be?

85. Is there anything about this case which causes you to have any feelings of prejudice or

sympathy one way or another?

FINAL QUESTION

86. Is there anything else that the judge or lawyers should know about you that could

affect your ability to serve as an impartial juror on this case?

Dated: January 10, 2025 GREENE ESPEL PLLP

s/ Surya Saxena
Surya Saxena, Reg. No. 0339465
Nicholas Scheiner, Reg. No. 0402470
222 S. Ninth Street, Suite 2200
Minneapolis, MN 55402
ssaxena@greeneespel.com
nscheiner@greeneespel.com
(612) 373-0830

Attorneys for Defendant Abdulkadir Nur
Salah

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