The jurors were asked about past sexual abuse.
View attachment 328563
Commented [A25]: GOVERNMENT OBJECTION: The Government objects to the next series of questions proposed by the defendant that are in green color font. The Government objects on the grounds that these questions are inappropriate, argumentative, confusing, and excessively detailed. The defendant’s proposed questions are not streamlined in accordance with the Court’s Order. The Government submits that its proposed questions ask the jurors what is necessary on the subject but is not as unduly burdensome as the defendant’s proposal.
Commented [A26R25]: DEFENDANT RESPONSE: Juror's personal experiences (directly or indirectly through family members and close friends) with sexual misconduct has significant potential to bias their opinions towards Ms. Maxwell based on the allegations and evidence in this case. The privacy of a questionnaire affords an opportunity to share these biases confidentially and candidly and best allow the parties to identify who cannot be a fair juror in this case or allows the Court to decide whether individual questioning of that juror is appropriate, based on the sensitive nature of the content of the questions.
https://storage.courtlistener.com/r...d.539612/gov.uscourts.nysd.539612.367.0_1.pdf