Stein Entry 177 Government Witnesses

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA, §

§ Plaintiff, § §

vs. § Case No 11-80205-CR-MARRA/HOPKINS §

MITCHELL J. STEIN, § §

Defendant. § ____________________________________/

UNITED STATES’ PROPOSED VOIR DIRE QUESTIONS

COMES NOW the United States of America, by and through its undersigned attorneys,

and respectfully submits the following proposed voir dire questions, pursuant to the Court’s

order of February 13, 2012 (Dkt. No. 23.)

1. Do any of you know the defendant, Mitchell J. Stein?

2. Do any of you know Charles G. White, standby counsel for Mitchell J. Stein?

3. Do any of you know or recognize Albert Stieglitz or Kevin Muhlendorf, the prosecutors

in this case, Eric Sweeney or Dan McConville (who may replace Mr. Sweeney during

this trial), paralegals in the case, or United States Postal Inspector George Clark, all of

whom will be sitting behind counsel table during trial?

4. Have you, any member of your family, or any close friend transacted business with, or

worked for, HeartTronics, Inc., formerly doing business as Signalife, Inc., and Recom

Managed Systems, Inc.?

5. Have you, any member of your family, or any close friend transacted business with,

worked for, or been indebted to, any casino or other gambling establishment?

Case 9:11-cr-80205-KAM Document 177 Entered on FLSD Docket 05/02/2013 Page 1 of 5

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6. Are you or any member of your immediate family a registered representative associated

with a securities broker-dealer, that is, a licensed stockbroker?

7. A list of names of possible witnesses or persons whose names might be mentioned during

this trial is as follows; do any of you know or recognize any of them?

Potential Government Witnesses

Potential Defense Witnesses Others

1. Ajay Anand 2. Jennifer Black 3. Michael Boliek 4. Pamela Bunes 5. Martin Carter 6. George Clark 7. Tim Cutter 8. Lee Ehrlichman 9. Bryan Harris 10. Tracy Jones 11. Jennifer McEwin 12. Peter Melley 13. Evie Muscillo 14. Mark Nevdahl 15. Kevin Pickard 16. Tom Tribou 17. Richard Wilk 18. John Woodbury 19. Jamie Yafa

1. Daphne Bell 2. James Fiedler 3. Joseph Galli 4. Willie Gault 5. Tracey Hampton-Stein 6. William “Bill” Matthews 7. Rowland Perkins 8. Norma Provencio 9. Jared Scharf 10. Gary Slossberg 11. Adam Usdan 12. Sam Wolff 13. Christina Carter 14. Budimir Drakulic 15. David Jones 16. Kenneth Londoner 17. Tom Ronk 18. Jane Greene 19. Cranford Scott 20. Clair LaFrance 21. Alaine Sosebee 22. Susan Keitt 23. Adam Eisner 24. Eric Wittenberg

1. Lowell Harmison 2. Rachel Nonaka

8. Is there anyone who would believe, or disbelieve, the testimony of a law enforcement

agent solely because he or she is a law enforcement agent?

9. Have you or any member of your family had any problems, a dispute with, or claim

against, any department of the United States Government, including the Department of

Justice?


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10. Have you or any member of your immediate family, been the subject of an investigation

by any agency of the United States Government, or ever been a defendant in a suit

brought by the United States Government?

11. Has anyone served as a juror in a criminal or civil trial or as a member of a grand jury in

Federal or State court?

[If any juror indicates that he or she has so served, it is requested that the following

inquiries be made]

a. Without going into the nature of the case, would you please answer the following

questions:

i. Did you serve on a grand jury or a petit jury?

ii. Where did you serve? In a Federal or State court?

iii. When did you serve?

iv. Was it a civil or a criminal case?

v. Was the case given to the jury for deliberation?

vi. Without stating the verdict, would you please state whether the jury

returned a verdict?

b. Do you feel that your previous participation as a juror would in any way impair or

interfere with your ability to serve as a fair and impartial juror in this case?

12. Have you or any member of your immediate family ever participated in a criminal case as

a complainant, a defendant, a witness for the Government or defense or in some other

capacity?

[If any juror indicates participation, it is requested that the following inquiries be made

at the bench]


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a. Was this a Federal, State, or local proceeding?

b. Without going into detail, would you please describe the nature of your

involvement?

13. Has anyone seen, read, or heard any media reports about this case?

14. Is there anyone who feels that if he or she were selected to sit as a juror on this case, he or

she would be unwilling or unable to render a verdict based solely on the evidence

presented at this trial and the law, which I will instruct you on at the conclusion of trial?

15. Does anyone have any other matter which you feel you should call to my attention that

may have some bearing on your qualifications as a juror or which you feel may prevent

you from rendering a fair and impartial verdict based solely upon the evidence and my

instructions?

Respectfully submitted,

JEFFREY H. KNOX Chief Dated: May 2, 2013 By: _____________/s/__________ ALBERT B. STIEGLITZ, JR. Assistant Chief

KEVIN B. MUHLENDORF Trial Attorney

Criminal Division, Fraud Section United States Department of Justice 1400 New York Ave., NW Washington, D.C. 20005 Phone: (202) 514- 4313 (Stieglitz) Fax: (202) 514- 0152 Email: [email protected] [email protected]


CERTIFICATE OF SERVICE

I hereby certify that on May 2, 2013, I electronically filed the foregoing document, with

its attachments, with the Clerk of Court using CM/ECF, which will send a notification of such

filing (NEF) to the following:

Mitchell J. Stein 1551 North Flagler Drive

Suite 1208 West Palm Beach, FL 33401

____________/s/________________ Albert B. Stieglitz, Jr. Assistant Chief


Documents

Stein Entry 177 Government Witnesses