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Home Source documents The Government’s Proposed Voir Dire Questions — No. 23 CR 97 (Dkt. 133, N.D. Ill.)

The Government’s Proposed Voir Dire Questions — No. 23 CR 97 (Dkt. 133, N.D. Ill.)

Summary

The government's proposed voir dire questions in United States v. Te Dora Brown, No. 23 CR 97, in the U.S. District Court for the Northern District of Illinois before the Honorable Elaine E. Bucklo, filed May 6, 2026 as Document 133 by the U.S. Attorney's office. The questions, offered in addition to the court's general voir dire, tell jurors that the case involves an investigation by the United States Secret Service and the Small Business Administration and that Brown is charged with wire fraud and has pleaded not guilty, and ask whether dealings with those agencies or the nature of the charges would affect their verdict. Others cover arrests or crimes involving jurors, family or friends, work in the criminal justice system, following the court's instructions on the law, podcast and television habits, and prior jury service.

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Full text

   Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 1 of 4 PageID #:542




                         UNITED STATES DISTRICT COURT
                         NORTHERN DISTRICT OF ILLINOIS
                              EASTERN DIVISION

 UNITED STATES OF AMERICA
                                                 No. 23 CR 97
           v.
                                                 Honorable Elaine E. Bucklo
 TE DORA BROWN

        THE GOVERNMENT’S PROPOSED VOIR DIRE QUESTIONS

      The United States of America, through its attorney, ANDREW S. BOUTROS,

United States Attorney for the Northern District of Illinois, respectfully proposes the

Court ask the following questions to all potential jurors, in addition to the Court’s set

of general voir dire questions:

      1.        Do you have any problem with your hearing, vision, or health that would

make it difficult for you to serve as a juror?

      2.        Do you have difficulty reading, speaking, or understanding English?

      3.        Do you hold any religious, philosophical, moral, or other beliefs that

would prevent you from returning a verdict in this case?

      4.        This case involves an investigation by the United States Secret Service

and the United States Small Business Administration. Have you, a family member,

or a close friend had any experiences or dealings with the United States Secret

Service, the United States Small Business Administration, the federal government,

or any law enforcement entity that might affect your ability to evaluate the evidence,

to deliberate with the jury, or to return a verdict in this case?




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   Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 2 of 4 PageID #:543




        5.      Have you, a family member, or a close friend ever been arrested for,

charged with, or convicted of any criminal offense other than a minor traffic violation?

If yes, please indicate the nature of the offense; the law enforcement organization

responsible for the arrest; the prosecutor’s office responsible for pursuing the charges;

what happened in the case; and whether anything about that experience might affect

your ability to evaluate the evidence, to deliberate with the jury, or to return a verdict

in this case.

        6.      Have you, a member of your family, or a close friend, ever been the

victim of a crime? If so, please indicate the victim’s relationship to you; the nature of

the offense; whether charges were brought against the offender; the disposition of

those charges; and whether anything about that experience might affect your ability

to evaluate the evidence, to deliberate with the jury, or to return a verdict in this

case.

        7.      Have you ever worked in the criminal justice system? If yes, please

explain the circumstances.

        8.      Do you have any close friends or relatives who are prosecutors or

criminal defense attorneys? Is there anything about your relationships with them

that would prevent you from evaluating the evidence, deliberating with the jury, or

returning a verdict in this case?

        9.      Defendant in this case is charged with wire fraud. She has pleaded not

guilty to these charges. Is there anything about the nature of these charges that




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   Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 3 of 4 PageID #:544




might affect your ability to evaluate the evidence, to deliberate with the jury, or to

return a verdict in this case?

      10.    At various times during the case, the Court will instruct you about the

applicable law. It is your obligation to follow the Court's instructions about the law,

whether you agree with the law or not. If you were to find that you disagreed with

the law as given to you by the Court, would you still be able to follow that law and

reach a verdict by applying that law to the evidence in this case?

      11.    What podcasts and/or radio programs you listen to regularly?

      12.    What television shows do you watch regularly?

      13.    Are there any other facts or circumstances that you believe the Court or

the parties should know about concerning your ability to serve as a juror in this case?




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   Case: 1:23-cr-00097 Document #: 133 Filed: 05/06/26 Page 4 of 4 PageID #:545




      To the Court’s general voir dire question regarding prior jury service, the

government proposes the following additions:

      14.    If you have previously served on a jury, please let us know the following:

(a) whether the case was in federal court or state court; (b) whether it was a criminal

case or civil case; (c) without disclosing to us what the verdict was, whether the jury

was able to reach a verdict in the case; (d) whether you were the foreperson; and

(e) whether your experience being on a jury left you with an impression of the legal

system, judges, or attorneys—positive or negative—that might affect your ability to

evaluate the evidence, to deliberate with the jury, or to return a verdict in this case.


                                        Respectfully submitted,

                                        ANDREW S. BOUTROS
                                        United States Attorney

                                  By:   /s/ Mary Katherine McClelland
                                        MARY KATHERINE McCLELLAND
                                        QUINN FORD
                                        Assistant United States Attorneys
                                        219 South Dearborn Street, 5th Floor
                                        Chicago, Illinois 60604
                                        (312) 353-5300
Dated: May 6, 2026




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