Stein Docket Entry 161

7/30/2019 Stein Docket Entry 161

http://slidepdf.com/reader/full/stein-docket-entry-161 1/6

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA

FU DW M

AP2 2 S 2213

sTtveN M.t.ARIK REI

-ERK u s Dls; crs.n.d Fi-k. .w.p.B,NITED STATES OF AM ERICA

,

âPlaintift j

5MITCHELL J. STEIN, j

Defendant. jl

Case No 11-80205-CR-MARRA/HOPKlNS

DEFENDANT M ITCHELL J. STEIN'S PROPOSED VOIR DIRE OUESTIONS

Defendant M itchell Stein requests that the following questions, inter alia, be asked

during voir dire.

or close friends worked at the

Securities and Exchange Commission, the NASD, or any agency involved in regulating the

purchase and sale of publicly traded securities?

Have you or any members of your family

Have you or any members of your family had special experience or special

training in the purchase and sale of publicly traded securities?

Have you or any members of your family worked for a stock broker or

securities firm?

4. Do you presently own any investments, such as stock market shares or interest

in real property or limited partnerships? Have you ever invested in securities traded on what are

called Pink Sheets or the Over-the-counter Bulletin Boards?

Are you an active investor who buys and sells stocks frequently?

Case 9:11-cr-80205-KAM Document 161 Entered on FLSD Docket 04/30/2013 Page 1 of 6



Do you use a stock broker to assist you with investments, or any money-

management advisor?

7. Have m u had a bad experience in investment decisions or with any stock broker

or money m anagem ent advisor? If so, please explain.

8. Have you ever sued or participated in a lawsuit relating to investment losses?

Have you or any of your fam ily or friends been involved in a start-up business?

10. Have you or any Of m ur family or friends been involved in trying to raise money

for a start-up business?

1 1. Some of the Gtwernment's evidence may consist of testimony by alleged co-

conspirators or individuals who have entered into plea bargains with the Government,

seeking favorable treatment in return for assisting the Government's case. W hile it is perfectly

appropriate that such plea bargains occur, the law says that such witness testimony m ust be treated

carefully and received with great caution. ls there anyone who cannot do treat the testimony who

witnesses who have plead guilty carefully and with great caution?

Do any of m u have opinions regarding solneone advising or assisting other

persons to buy or sell stock that would make it ditxcult for you to fairly consider the testimony

and follow my instructions?

Has anm ne hard about a company called Recom, or Heart Tronics, or Signalife?

l4. Has anyone heard about an organization called Athletes for Life?

15. W ho here has lost a loved one, family member, and/or close friend to heart disease?

Who here has fam iliarity with EKG machines, EEC machines, heart monitors,

or related devices?

Who here has served on a board of directors or an audit committee of a company?

2




l8. Who here has any background in accounting or in auditing of public companies?

19. Who here knows what a IOK, aIOQ, an 8K, or an 8Q is? Who here has filed

or signed ofron such documents?

20. W ho here is aware of the rm uirements the Sarbanes-oxley 1aw places on

companies?

21. W ho here knows what shol't selling or naked short selling a stock means?

22. W ho here has fam iliarity with family trusts, or fam iliarity with blind trusts?

Do you know any reason why you may be prejudiced for or against the

government for or against any witness, or for or against Mr. Stein, whether because of the nature

of the charges or otherwise? lf so, would prevent you from being fair and impartial to both sides

in this case?

24. Do you have any bias or prejudice concerrling the Department of Justice, the

Fedel'al Bureau of Investigation, or law enforcement generally, or people accused of fraud

generally, that would lead you to be prejudiced either in favor of or against the government or

Mr. Stein? lf so, please explain.

Do you have any opinions,religious beliefs, philosophies, or prejudices

which would make you unable to come to a verdict in this case? For example, do you believe

that no person should ever be judged or convicted, or that you could not sit in judgment of

another person? On the other hand, do you believe that anyone accused of fraud should be

convicted?

Are m u active in any organizations, social clubs, or civic groups? W hich? Do you

regularly attend Church? Do you hold any position with your Church?




n e law says that the accused, M r. Stein, enters this courtroom presumed

innocen: and remains innocent unless the prosecution establishes guilty beyond a reasonable

doubt. M r. Stein, who is a lawyer, is trying this case himself. Do you have any diflkulty in

presuming that M r. Stein is innocent? Does his self-representation cause you to hesitate in that

conclusion?

4




28. Do you accept the law that a defendant is not required to prove his or her

innocence and is not required to testify or oflkr any evidence on his or her behalo

Could you follow the Court's instruction that you may not consider the indictment

as any evidence of guilt?

30. Do any of you feel that, because a person is accused of a crime by the

Governmenta he is probably guilty?

Respectfully subm itted,*'

M itchell J. Stein,Pro Se,. Phone: 56 1 -350-6 1 36,. Email:

private.oceibod@gmail .com ;Address.. 1 55 l N.Flagler Dr., h'estPalm Beactl, Florida33401




CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing docum ent has been

filed via electronic mail with the Clerk ofthe Court by using CM/ECF System which will send a

notice of electronic filing to the following counsel of record or pro se parties identified in the

Service List below in the manner specified, either via transmission of Notices of Electronic

Filing generated by CM /ECF or in some other authorized manner for those counsel or parties

who are not authorized to receive electronically Notices of Electronic Filing on this 17th day of

April 28, 2013

Albert Steiglitz, Esq.

Kevin B. M uhlendortl Esq.U.S. Department of Justice

Crim inal Division - Fraud Sectionth yjoor400 New York Avenue

,4

Washington, DC 2005

.

x. .Nyyy

W ùf bW -


Documents

Stein Docket Entry 161