Jointly Proposed Voir Dire — United States v. Emmet Bowens (Dkt. 202)
Summary
Jointly Proposed Voir Dire filed December 15, 2025, as Document 202 in United States v. Emmet Bowens, Case No. 6:21-cr-141-RBD-NWH, United States District Court, Middle District of Florida, Orlando Division. The United States and the defendant, through counsel, jointly submit proposed questions for prospective jurors and ask that the Court allow follow-up questions. The questions cover occupation, accounting training, business ownership, and applications for a Paycheck Protection Program or Economic Injury Disaster Loan. Question No. 4 recites the allegation that Emmet Bowens defrauded the federal government and banks through false applications to the United States Small Business Administration. Later questions ask about arrests, serving as a witness and accepting the law as the Court gives it.
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“Jointly Proposed Voir Dire — United States v. Emmet Bowens (Dkt. 202).”
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Case 6:21-cr-00141-RBD-NWH Document 202 Filed 12/15/25 Page 1 of 20 PageID 555
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
UNITED STATES OF AMERICA
v. Case No. 6:21-cr-141-RBD-NWH
EMMET BOWENS
JOINTLY PROPOSED VOIR DIRE
The United States and the defendant, through his undersigned counsel, jointly
submit the following proposed voir dire questions. 1 The parties request that the
Court allow follow-up questions that may reasonably follow from the answers
received.
Respectfully submitted,
GREGORY W. KEHOE
United States Attorney
By: /s/ Michael W. Nielsen By: /s/ Rachel S. Lyons
Michael W. Nielsen, Esq. Rachel S. Lyons
Florida Bar No. 794392 Special Assistant United States Attorney
Smith & Eulo Law Firm USA No. 215
720 W State Road 434 400 W. Washington Street, Suite 3100
Winter Springs, FL 32708 Orlando, Florida 32801
mnielsen@smithandeulo.com Telephone: (407) 648-7500
sroofe@smithandeulo.com Facsimile: (407) 648-7643
sfetterman@smithandeulo.com E-mail: Rachel.Lyons@usdoj.gov
(407) 327-5865
Counsel for Emmet Bowens
1
Counsel have conferred and agreed to the proposed verdict form. However, counsel note
that a Faretta hearing is set for December 16, 2025, to address whether the Defendant
intends to proceed pro se.
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Page 2 of 20
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JOINTLY REQUESTED VOIR DIRE NO. 1
Please state your full name.
What is your occupation? If you are retired or not currently working, please
state what your last employment was.
Are you married?
Is your spouse employed? If so, what type of work do they do?
Do you have any children of working age?
If so, how many, and what type of work do they do?
Page 3 of 20
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JOINTLY REQUESTED VOIR DIRE NO. 2
Do you have any education or training in accounting?
Does any member of the jury panel own or run a business?
If so:
a. For how long have you owned or run your business?
b. How many employees do you have?
Page 4 of 20
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JOINTLY REQUESTED VOIR DIRE NO. 3
Do you belong to any social, civic, religious, or professional organizations? If
so, what organization? How long have you been a member? What is the
purpose/mission statement of the organization?
Page 5 of 20
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JOINTLY REQUESTED VOIR DIRE NO. 4
This case involves allegations that the defendant, Emmet Bowens, defrauded
the federal government and banks by submitting false applications to the United
States Small Business Administration (“SBA”) in 2020 in connection with the
Paycheck Protection Program. Do any of you have personal knowledge of the facts
of this case, or about the defendant, which has not come from what you have learned
in court so far today?
Page 6 of 20
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JOINTLY REQUESTED VOIR DIRE NO. 5
Have you, any member of your immediately family, a close friend, or your
employer, applied for a Paycheck Protection Program (“PPP”) loan?
a. In what business name was the application filed?
b. Was the loan funded?
Have you or any member of your immediately family applied for an
Economic Injury Disaster Loan (“EIDL”) loan?
a. In what business name was the application filed?
b. Was the loan funded?
Do you have strongly held views about the Coronavirus Aid, Relief, and
Economic Security Act (“CARES”) that would impact your ability to be a fair and
impartial juror in this case?
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JOINTLY REQUESTED VOIR DIRE NO. 6
Have you or any of your friends or family ever been employed by a bank,
mortgage lender, or mortgage broker in any capacity?
Who?
When?
Where?
What were your/their job responsibilities?
Page 8 of 20
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JOINTLY REQUESTED VOIR DIRE NO. 7
The attorneys for the United States have advised me that in this case, the
government allegedly lost money because of the actions of the defendants alleged in
the indictment.
Does any member of the jury panel feel that you might treat the allegations of
criminal conduct in this case as less serious or less important because it was the
government, and not an individual, that may have suffered a loss because of that
criminal conduct?
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564
JOINTLY REQUESTED VOIR DIRE NO. 8
The defendant is on trial for his actions as alleged in the indictment. No other
person is on trial in this case.
Can you decide this case based upon the evidence offered and not allow your
verdict to be affected by any evidence about any other person mentioned during the
trial?
Page 10 of 20
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565
JOINTLY REQUESTED VOIR DIRE NO. 9
Does any member of the jury panel have any strong feelings or opinions
concerning the United States government or, more specifically, the U.S. Small
Business Administration, IRS, or FBI, which might in any way affect your ability to
be a fair and impartial juror in a case such as this?
Has any member of the jury panel ever had a bad or negative experience with
an employee of any of the agencies I just named? If so, what happened?
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566
JOINTLY REQUESTED VOIR DIRE NO. 10
Do you have any member of your family, close friend, or acquaintance who is
involved in law enforcement, including the FBI, IRS, or any other state or federal
law enforcement agency?
If so, who do you know? What does that person do? What is the nature of
your relationship to that person?
Could the fact that you have such a friend or relative in any way affect your
ability to be a fair and impartial juror sitting in a criminal case and evaluating the
testimony of law enforcement officers?
Does any member of the jury panel have any opinions about the FBI, IRS, the
SBA, or any other federal, state, or local law enforcement agency that would affect
your ability to render a fair and impartial verdict in this case?
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567
JOINTLY REQUESTED VOIR DIRE NO. 11
Have you ever served on a jury before, either in state court or in federal court?
If so, when did you serve? Where?
What type of case was it?
Were you the foreperson?
Did the jury reach a verdict?
Was there anything about your experience as a juror that would affect your
ability to sit as a fair and impartial juror in the present case and concerning the
present charges?
If you previously sat as a juror in a case, the law that you may have been told
in that case may differ from the law that related to the present case. Can you assure
the Court and both counsel that you will obey and follow the law as I instruct you,
even if it is contrary to what you might have been told in the case(s) on which you
previously sat as a juror?
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568
JOINTLY REQUESTED VOIR DIRE NO. 12
Does any member of the jury panel have any matter pending before the
United States Attorney’s Office in this district or any other district in which you are
involved as a party, witness, or subject of some legal action?
If so, please explain the type of matter and what your involvement is.
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569
JOINTLY REQUESTED VOIR DIRE NO. 13
Have you, any member of your family, or close friend, ever been the victim of
a crime?
If so, who?
What happened?
When did this happen?
Was the person who committed the crime identified, prosecuted, and
convicted?
If so, did you have to speak to police, appear in court, or give testimony in
that regard?
Were you satisfied with the outcome?
Is there anything in that experience that could affect your ability to be fair and
impartial both to the defendant and to the United States?
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570
JOINTLY REQUESTED VOIR DIRE NO. 14
Has any member of the jury panel ever served as a grand juror, either in state
or federal court?
If so, when and where?
Is there anything in that experience that would affect your ability to be fair and
impartial both to the defendant and to the United States?
The law with respect to the burden of proof in grand jury proceedings is
different from the law that would relate to these charges. Can you assure the Court
and counsel that you will obey and follow the law as I instruct you, even if it is
contrary to what you might have been told in the case(s) on which you previously sat
as a grand juror?
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571
JOINTLY REQUESTED VOIR DIRE NO. 15
Has any member of the jury panel, or any family member, relative, or close
friend or acquaintance of yours, ever been investigated by any federal, state, or local
law enforcement agency?
If so, what was the subject of the investigation? What was the outcome of the
matter?
Have you or any family member, relative, or close friend ever been
arrested, charged, or convicted of any crime?
If so, what was the crime or allegation? What was the outcome of the case?
Would this experience impact your ability to fairly and impartially assess the
evidence and testimony of the witnesses who will testify on behalf of the United
States?
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572
JOINTLY REQUESTED VOIR DIRE NO. 16
Have you been a witness in any type of court or judicial proceeding?
If so, what type of proceeding did you give testimony?
Were you subject to cross-examination by attorneys for either side in that case
or proceeding?
If your answer to any of these questions was yes, do you feel that your
experience as a witness could in any way affect your ability to fairly and impartially
evaluate the testimony of the witnesses who will testify in this case?
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573
JOINTLY REQUESTED VOIR DIRE NO. 17
Do any among you have any conscientious objection, religious belief, or other
mental reservation such that you could not, in good faith and in good conscience, sit
as a juror in this criminal case and return a verdict of guilty, even if you believed that
the United States has proved its case beyond a reasonable doubt?
To put it another way, is there anyone here who feels that, for any moral or
religious reasons, he or she cannot sit in judgment of another human being?
Your verdict must be based on the facts of the case and on the evidence. Your
duty, as jurors, is to judge guilt or innocence based upon the evidence. It is the duty
of the judge to instruct you on the law and to determine punishment if you vote
guilty. The law does not permit you to consider emotion, sympathy, prejudice,
vengeance, fear, or hostility. Do any of you believe that you would have difficulty
following this rule?
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574
JOINTLY REQUESTED VOIR DIRE NO. 18
If you are selected as a juror in this case, you will take an oath to render a
verdict based upon the law as given to you by the Court. You will be required to
accept the law as given to you by the Court without regard to any personal opinion
you may have as to what the law is or should be. If you do not agree with the law,
who here will have difficulty reaching a verdict in accordance with the law as given
to you in the instructions of the Court?
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