Joint Proposed Voir Dire — United States v. Ryan E. Dales

Summary

A Joint Proposed Voir Dire filed October 14, 2024, as Document 73 in United States v. Ryan E. Dales, Cr. No. GLR-23-026, Case 1:23-cr-00026-GLR, in the U.S. District Court for the District of Maryland. The United States and the Defendant request that the Court conduct the listed interrogation of prospective jurors under Federal Rule of Criminal Procedure 24(a). The filing says the Government used the Court's standard voir dire questions, with added language highlighted in yellow and proposed deletions stricken in red. The opening statement to the jury lists the charges as Felon in Possession of a Firearm, 18 U.S.C. § 922(g)(1); Possession With Intent to Distribute Fentanyl, 18 U.S.C. § 841(a)(1); and Possession of a Firearm in Furtherance of a Drug Trafficking Activity, 18 U.S.C. § 924(c)(1)(A)(i), and says the case is expected to last no more than 5 days.

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“Joint Proposed Voir Dire — United States v. Ryan E. Dales.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-mdd-529188-73-0-ddb8554ae4/, SHA-256 0d78116511ed63eddc3cf688415dcdff112416ef622500ea0eee91483a887b12.

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Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
NORTHERN DIVISION

UNITED STATES OF AMERICA *
*
v. * CR. NO. GLR-23-026
*
RYAN E. DALES, *
*
Defendant. *
*******
JOINT PROPOSED VOIR DIRE

By and through the undersigned, the United States of America and the Defendant request

the Court to conduct the following interrogation of prospective jurors pursuant to Federal Rule of

Criminal Procedure 24(a).

The Government used the Court’s standard voir dire questions in preparing this

submission. Proposed voir dire questions and language not included among the Court’s standard

questions are highlighted in yellow. Any items that the parties propose to delete from the

Court’s standard questions are stricken in red.

*****
I. Members of the Jury:

A. My name is George Russell, and I am the Chief Judge for the United States District Court

for the District of Maryland. The case now under consideration is: The United States of

America v. Ryan E. Dales. Mr. Dales is charged with Felon in Possession of a Firearm, in

violation of 18 U.S.C. § 922(g)(1); Possession With Intent to Distribute Fentanyl, in

violation of 18 U.S.C. § 841(a)(1); and Possession of a Firearm in Furtherance of a Drug

Trafficking Activity, 18 U.S.C. § 924(c)(1)(A)(i). This case is expected to last no more

than 5 days.
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 2 of 10

A. I am going to ask you some questions in order to obtain certain information that may be

helpful to the lawyers in the selection of a jury in this case. Your legal requirement in

responding to these questions is the same as if each of you took the stand and testified

under oath. As it is impossible to question each of you individually, the questions will be

asked of you as a group. This part of the proceeding is a vital and important function of

the judicial process. In asking you questions to which you must respond, both parties and

the Court are able to determine if you are eligible to participate as a juror. For example,

if you are related to or friends of the attorneys of the defendant(s), this is an important fact

which should be known.

B. It is emphasized that the fact that you are questioned as a group does not lessen your

obligation to accurately and truthfully make known your answers in response to the

questions which are to follow. The ability of this Court to obtain jurors who are free of

prejudice and who are not related to, or friends of, the parties is an important inquiry, as

are all of the other questions which you will be asked.

C. I am going to ask you some questions in order to obtain certain information that may be

helpful to the lawyers in the selection of a jury. If you answer YES to any question, please

rise. When recognized, please give your juror number only. If it is necessary to answer

out of the hearing of the other jurors, I will have you come up to the Bench and answer at

that time.

D. For an affirmative response, I will ask you the following question: “Would that fact,

relationship or experience prevent you from rendering a fair and impartial verdict based

solely on the evidence produced?”
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 3 of 10

VOIR DIRE

The case now under consideration is United States of America v. Ryan Dales. As noted,

Mr. Dales is charged with Felon in Possession of a Firearm; Possession With Intent to Distribute

Fentanyl; and Possession of a Firearm in Furtherance of a Drug Trafficking Activity.

1. Other than what I just told you, do you know anything at all about this case either through

your own personal knowledge, through media reports or social media, or any discussion

with anyone else?

2. Ladies and gentlemen, in this case, the Defendant is Ryan Dales. Will the Defendant please

stand and face the jury? Does anyone know Mr. Dales, or has any member of the jury

pool maintained a business or social relationship either in the past or the present with Mr.

Dales? You may be seated.

3. Mr. Dales is represented by counsel. Mr. Bardos, please stand and face the jury. Does

anyone know Mr. Bardos, or has any member of the jury panel maintained a social

relationship with, or been represented or opposed by, counsel for the Defendant, Mr

Bardos?

4. The United States of America is represented by United States Attorney Erek Barron and

Assistant United States Attorney Paul Riley. Does anyone know Mr. Barron or Mr. Riley?

5. Again, my name is George Russell. Does anyone know me or anyone on my judicial staff?

6. The following persons may be called as witnesses or mentioned in this matter. Please pay

attention to their names. It is necessary that we are aware if you know any of them: [read

list of names provided]

Does anyone know or recognize any of the possible witnesses or individuals just named?
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 4 of 10

7. Look around at the other members of the jury pool. Does anyone member of the panel

know any other member of the panel?

8. Would any member of the jury panel be inclined to give either more or less weight to the

testimony of a police or law enforcement officer than to any other witness in the case,

merely because he/she is a police officer? [Moved later in voir dire.]

9. I will now ask you some questions relating not only to you, but also to members of your

immediate family. By this I mean, spouse, parents, children, brother or sister, or anyone

residing with you. It does not mean aunts, uncles, cousins, nieces, nephews, or in-laws

unless they live with you.

10. Has any member of the jury panel, or members of your immediate family, ever been

employed by or connected with any law enforcement agency, such as any police

department, sheriff’s office, state or federal prosecutor’s office, the FBI or other federal

law enforcement agency office, the military police, or any correctional facility? of the

public defender, FBI, law firm, correctional officer or military police?

11. Has any member of the panel, or members of your immediate family ever been employed

by a public defender’s office, whether state or federal, a private criminal defense attorney,

or any other entity that provides services to persons charged with or convicted of a crime?

12. Has any member of the jury panel, or members of your immediate family, ever been

connected with any court or court-related agency?

13. Has any member of the jury panel, or members of your immediate family, been employed

in this courthouse in any capacity or acquainted with any employee in the courthouse?

This case was primarily investigated by the FBI and the Department of Labor – Office of Inspector

General.
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 5 of 10

14. Has any member of the jury panel, or members of your immediate family ever been

employed by, had dealings with, or been in a dispute with the FBI or the other agency I

just mentioned?

15. Do you have an opinion, favorable or unfavorable, concerning the veracity or credibility

of law enforcement officers who are members of the FBI or any other police department

or law enforcement agency?

16. [Have you, or any member of your family, ever been the victim or witness to domestic

violence or worked for a domestic violence program?]

17. Does any member of the panel hold such strong feelings involving drugs that you would

be unable to follow the instructions that I will give you regarding the law that applies in

this case? For example, do you feel so strongly that narcotic drugs should be legalized that

you could not apply the law as I explain it to you?

18. This question has several parts, so please listen carefully. Do not answer until I have

completed the question.

a. Has any member of the jury panel, or any member of your immediate family,

ever been the victim of a crime?

b. Does any member of the jury panel have a charge, other than traffic, pending

against them in which the penalty is imprisonment for more than six months, or

a fine of more than $500.00, or both? [Source: Courts and Judicial

Proceedings, Section 8-207(b)(5).]

c. Have you, any member of your family, or any of your close friends ever been

charged, arrested, or accused of criminal conduct or ever been the subject of a
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 6 of 10

criminal investigation, whether it be federal, state, or local? This includes

serious traffic offenses, DUI or DWI, and drug possession, among other things.

d. Has any member of the jury panel, any member of your immediate family, or

close friends ever been arrested or convicted of a crime?

e. Has any member of the jury panel, or any member of your immediate family,

ever been a witness to a crime?

f. Has any member of the jury panel, or any member of your immediate family,

ever been a witness for the prosecution or the defense in a criminal case?

19. Have you, any member of your family, or any of your close friends ever attended a law

school, taken a paralegal course, received legal education or training of any kind, or worked

with a lawyer, law firm, in a courthouse, or as a paralegal, legal secretary, or private

investigator?

20. Is any member of this panel presently a party in any case (civil or criminal) pending in this

or any other federal or state court?

21. Has any member of the jury panel ever served on a grand jury in either state or federal

court?

22. Has any member of the jury panel ever served as a juror in a criminal case in either state

or federal court?

a. If so, in what court did you serve as a juror, what charges were involved in the

trial, and what was the result of the trial?

b. Do you believe the case was fairly decided?

c. Did anything happen during your prior jury service which would influence you

in any way in deciding this case in a fair and impartial manner?
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 7 of 10

23. Has any member of the panel, or members of your immediate family been involved in any

legal dispute with any federal, state, or local government, or any agency thereof, including

but not limited to the Department of Justice, the Internal Revenue Service, the FBI, or the

Baltimore County Police Department, or does any department or agency of the Government

have a claim against you, any member of your family, or any of your close friends?

24. Has any member of the panel had a negative experience with, or does anyone have negative

feelings toward, or have any reservations or opinions about prosecutors or the U.S.

Department of Justice?

25. Has any member of the panel had a negative experience with, or does anyone have negative

feelings toward, or have any reservation or opinions about defense attorneys, or others

employed in criminal defense work?

26. During this trial, a number of the witnesses called by the government may be state or

federal law enforcement officers. Would any member of the jury panel be inclined to give

either more or less weight to the testimony of a police or law enforcement officer than to

any other witness in the case, merely because he/she is a police officer?

27. Would any member of the panel tend to give more or less weight to the testimony of a

witness called by the prosecution?

28. Would any member of the panel to give more or less weight to the testimony of a witness

called by the defense?

29. Does any member of the panel, any members of your family, or any of your close friends

belong to any group that advocates a change in our criminal justice system or our criminal

sentencing guidelines, including any group which advocates a position on the reduction or

increase in prison sentences?
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 8 of 10

30. Does any member of the panel have any reservations concerning the administration of

criminal justice in the courts that would prevent you from rendering a fair and impartial

verdict in this case?

31. At the end of this trial, I will instruct you on the law which must be followed in this case.

Even if you personally did not agree with the law as I describe it to you, is there anyone

who would hesitate—or who would be unwilling or unable—to follow my instructions on

the law? If you have an opinion on what the law should be, and your opinion was different

from my instructions on what the law is, would anyone hesitate—or be unwilling or

unable—to follow my instructions on the law?

32. Jurors will be instructed that they may not research anything about the case on the internet

or elsewhere, and that they must avoid any reports or information about the case or the trial

in the media, on the internet or on social media. Would you be able to obey such an

instruction during the course of the trial?

33. The Court will instruct you that an indictment is merely an allegation and is not proof of

anything. Do any of you believe that simply because a defendant has been arrested or

charged with a crime the defendant is guilty?

34. Under our Constitution, there is a presumption that every person charged with a criminal

offense is presumed innocent unless and until proven guilty beyond a reasonable doubt.

Would you have any difficulty in applying this presumption?

35. The burden rests with the prosecution to prove the charged offenses beyond a reasonable

doubt. Under the law, a defendant in a criminal case is not required to explain his or her

side of the case and has an absolute right not to testify. Do any of you not understand those

principles or have any problem applying them?
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 9 of 10

36. If selected to serve as a juror in this case, you will be instructed that you are not to consider

punishment as that is for the Court to decide. You are not to speculate whatsoever about

what the possible punishment in this case might be if the defendant is found guilty of any

of the offenses with which he is charged. Would any member of the panel be unable to

put any consideration of punishment out of your mind and consider only the facts of the

case based on the evidence introduced?

37. Is there any other matter, fact or thing, including philosophical or religious beliefs which

would affect your ability to give a fair and impartial verdict in this case?

38. Does anyone on the panel have any bias or prejudice based on race, sex, age, or any other

characteristic that would prevent you from rendering a fair and impartial verdict in this

case?

39. Does anyone on the panel have any impairment of your vision or hearing that might make

it difficult for you to see and hear the witnesses during the trial?

40. Does anyone on the panel have any difficulty understanding the English language to the

extent that it would prevent you from following the testimony in this case?

41. Is anyone on the panel taking any medication that might make you unable to give your full

attention to the evidence presented?

42. Does anyone on the panel suffer from any physical or mental illness or condition that would

affect your ability to serve as a juror in this case for any reason?

43. Does anyone on the panel have any personal, family, or other considerations that would

make it difficult for you to serve as a juror for the full length of trial?

44. This trial will no more than five days (one week). If you are selected to sit on this case,

you are required by law to continue on jury duty until the case is completed. If any of you
Case 1:23-cr-00026-GLR Document 73 Filed 10/14/24 Page 10 of 10

have a compelling reason which makes it impossible for you to serve as a juror on this case

for that time, the Court has limited authority to excuse you. Therefore, if it is impossible

for you to serve as a juror, please stand.

45. If selected as a juror, you are required to render a fair and impartial verdict based upon the

evidence presented in the courtroom and the law as I describe it to you in my instructions

to you. Other than already expressed, does any member of the panel have is there any

reason you cannot do that?

46. Do you have anything else you wish to bring to my attention regarding your possible

service as a juror in this case about which I have not already asked you?

47. Is there any juror who is not a citizen of the United States and a resident of the State of

Maryland?

Respectfully submitted,

Erek L. Barron
United States Attorney

/s/
Paul A. Riley
Assistant United States Attorney

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