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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).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-flmd-396523-202-0-8e2ba728c6/, SHA-256 e35a5a223c57b1bc5e9e06d2ce6025d43a2f5ef82eaf858751ccd1bc99e10958.

Full text

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.
Case 6:21-cr-00141-RBD-NWH   Document 202   Filed 12/15/25   Page 2 of 20 PageID 556




                                 Page 2 of 20
Case 6:21-cr-00141-RBD-NWH     Document 202      Filed 12/15/25   Page 3 of 20 PageID 557




                    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
Case 6:21-cr-00141-RBD-NWH    Document 202     Filed 12/15/25   Page 4 of 20 PageID 558




                    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
Case 6:21-cr-00141-RBD-NWH      Document 202      Filed 12/15/25   Page 5 of 20 PageID 559




                    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
Case 6:21-cr-00141-RBD-NWH     Document 202     Filed 12/15/25   Page 6 of 20 PageID 560




                     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
Case 6:21-cr-00141-RBD-NWH        Document 202   Filed 12/15/25   Page 7 of 20 PageID 561




                      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?




                                      Page 7 of 20
Case 6:21-cr-00141-RBD-NWH     Document 202     Filed 12/15/25   Page 8 of 20 PageID 562




                    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
Case 6:21-cr-00141-RBD-NWH       Document 202      Filed 12/15/25   Page 9 of 20 PageID 563




                      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?




                                       Page 9 of 20
Case 6:21-cr-00141-RBD-NWH          Document 202     Filed 12/15/25    Page 10 of 20 PageID
                                           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
Case 6:21-cr-00141-RBD-NWH        Document 202       Filed 12/15/25   Page 11 of 20 PageID
                                         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?




                                      Page 11 of 20
Case 6:21-cr-00141-RBD-NWH        Document 202       Filed 12/15/25   Page 12 of 20 PageID
                                         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?




                                      Page 12 of 20
Case 6:21-cr-00141-RBD-NWH        Document 202      Filed 12/15/25    Page 13 of 20 PageID
                                         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?




                                       Page 13 of 20
Case 6:21-cr-00141-RBD-NWH        Document 202      Filed 12/15/25   Page 14 of 20 PageID
                                         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.




                                     Page 14 of 20
Case 6:21-cr-00141-RBD-NWH       Document 202      Filed 12/15/25    Page 15 of 20 PageID
                                        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?




                                     Page 15 of 20
Case 6:21-cr-00141-RBD-NWH        Document 202      Filed 12/15/25   Page 16 of 20 PageID
                                         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?




                                     Page 16 of 20
Case 6:21-cr-00141-RBD-NWH       Document 202      Filed 12/15/25    Page 17 of 20 PageID
                                        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?




                                     Page 17 of 20
Case 6:21-cr-00141-RBD-NWH       Document 202      Filed 12/15/25    Page 18 of 20 PageID
                                        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?




                                     Page 18 of 20
Case 6:21-cr-00141-RBD-NWH        Document 202      Filed 12/15/25    Page 19 of 20 PageID
                                         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?




                                      Page 19 of 20
Case 6:21-cr-00141-RBD-NWH       Document 202      Filed 12/15/25    Page 20 of 20 PageID
                                        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?




                                     Page 20 of 20


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