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Civil Division

The Estate of Robert E. Wone, by Civil Case No. 0008315-09

Katherine E. Wone
Plaintiff, Hon. Brook Hedge
v.
Joseph Price Trial: October 17, 2011
Dylan Ward
Victor Zaborsky
Defendants,

   


This questionnaire is being submitted to you to assist the Court in selecting a jury to hear this case and
for determining your availability to serve as a juror. The information that you give in your answers will
be used only by the Court and the parties to select a qualified jury. After a jury has been selected, all
copies of your responses to the questionnaire will be returned to the Clerk of the Court and kept in
confidence, under seal, not accessible to the public or the media. Please fill out the entire questionnaire.
Do not leave any questions blank.

If a question does not apply to you in any way, write ͞N/A͟ rather than leaving the form blank. If you
cannot answer a question because you do not know the answer or do not understand the question,
write ͞Do not know͟ or ͞Do not understand.͟ Initial each page to indicate that you have completed it.

Respond to each question as fully and completely as possible. Please keep in mind there are no ͞right͟
or ͞wrong͟ answers, only complete and incomplete answers. Complete answers are far more helpful
than incomplete answers. Your complete truthfulness is necessary, however, so that a fair and impartial
jury may be selected. Please don͛t discuss your answers with anyone, including your family, friends, and
fellow jurors.

This instruction includes not discussing or communicating with others about this case, this questionnaire
or your potential jury service on this case by text message, email, Skype or through any blog or social
networking medium, including MySpace, Face book, YouTube, LinkedIn among others. If you require
additional space for your responses, or wish to make further comments regarding any of your answers,
please use the Explanation Sheet at the end of this questionnaire. Put the number of the question you
are answering on the Explanation sheet before you write the response or comment. Thank you for your
cooperation. PLEASE PRINT LEGIBLY ʹ PLEASE USE ONLY DARK INK _______ JUROR NUMBER

1. What is your age? _______

2. Are you: å Male å Female

3. Do you know or recognize any other prospective juror in this case? å Yes å No
If YES, please state the name of each other prospective juror you know and briefly explain how you
know him/her ______________________________________________

4. How long have you lived in Wash., DC?_______

In which quadrant do you live? å NW å NE å SW å SE
5. What is your employment status? (check as many as apply) Employed Full Time å Unemployed å
Homemaker å Disabledå Student (specify area of study) å Full time caretaker for dependent å
Employed Part Timeå Full time volunteer workerå Retiredå Other (specify) _________________

6. If employed, what is your current occupation? ____________________________________

7. How many years have you been employed in your current job? _____________
8. If you are no longer employed (retired or currently unemployed), what job or position did you last
hold and what kind of work did you do? __________________________________
When did you leave (or retire) from this job? ____________
9. What is the last grade you completed? (Check one) å No High School åSome High School
åHigh School or Equivalent (GED) åSome College (or training, certificate programs)
åCollege Degree (4 Year) åPost -College Training or Degree

10. Do you have any education, training, employment or volunteer experience in the following? Yes No
a. Law å å
b. Law enforcement å å
c. Criminal justice (prisons) å å
d. Forensic sciences å å
e. Surveillance/investigation å å
f. Medicine/health å å
g. DNA analysis å å
h. Handwriting analysis å å
If YES, please list and describe the training and/or courses: __________________________

11. Some of the events that will be described during the trial are alleged to have occurred in the DuPont
Circle Area, specifically, the 1500 Block of Swann Street, NW. How familiar are you with that area of DC?
(Check one) å Very Familiar å Somewhat familiar å Don͛t know the area at all

12. Have you ever served on a grand jury before? å Yes å No å

13. Have you ever served as a trial juror? å Yes å No å

Been to one or more of them once or twice Yes å No å

14. If you have served as either a grand juror or a trial juror, was there anything about your experience
that would make it difficult for you to sit and fairly judge this case?
å Yes å No If YES, please explain: _______________________________________________________

15. Have you, any members of your family, or any close friends worked as a lawyer or ever been
employed by a lawyer or a law firm, worked in a courthouse, been a paralegal, served as a legal
secretary or received any type of legal training? å Yes å No If YES, please explain. ___________

16. Have you, any members of your family, or any close friends ever been employed by, or made any
application for employment with local, state, or federal law enforcement, including but not limited to
any police department, any federal law enforcement agency or any local, state or federal prosecutor͛s
office, or the Department of Justice, or any correctional positions connected with a jail, a prison, or a
courthouse? å Yes å No If YES, please explain. ____________________________

17. Have you, any members of your family, or a close friend ever been employed by, or made any
application for employment with any individual attorney or any local, state, or federal organization
involved in criminal defense work, including but not limited to the District of Columbia Public Defender͛s
Service, the Georgetown Law Clinic, and/or the Innocence Project? å Yes å No If YES, please explain:
______________________________________________________
18. Do you or your family members or close friends belong to any group or organization that is active in
law enforcement, crime prevention or crime victims͛ rights, such as Crime Stoppers, Orange Hats,
Neighborhood Advisory Committees, or other related groups? å Yes å No If YES, please explain.
______________________________________________________

19. Do you, a family member, or a close friend, to your knowledge, have any strong favorable or
unfavorable feelings about law enforcement agencies such as the FBI, the Police Department, or the
United States Attorney͛s Office, or the agents, officers, and prosecutors who work for those agencies?
Or a private investigator? å Yes å No If YES, please explain: ________________________________

20. A number of trial witnesses may be either federal or state law enforcement officers. I will instruct
the jury, as I do in every case, that they cannot give either greater or lesser weight to the testimony of
law enforcement officers solely because of their status as such. In other words, you cannot have any
preconceived idea about the credibility of a law enforcement officer ʹ or any other witness, for that
matter ʹ and must make your determination of credibility and the weight of the officer͛s testimony
based solely upon his/her presentation as a witness in this courtroom. Do you feel for any reason that
you could not follow these instructions, and therefore would give the testimony of a law enforcement
officer greater or lesser weight simply because of his/her status of a law enforcement officer?
å Yes å No If YES, please explain: ____________________________________________________

21. Have you, a family member, or close friend, ever been the victim of, a witness to, or accused of a
crime of violence, a crime involving a weapon, or a crime involving sexual assault? å Yes å No
IF YES, please provide the following information for each person and incident. Relationship Type of
Crime Victim, Witness or Accused Outcome (self, sister, etc): _______________________________

22. Do you believe that you, any member of your family, or any close personal friend was ever falsely
accused of a crime? å Yes å No If YES, please explain: _______________________________________

23. During the trial, you may hear testimony from a witness who incarcerated for offenses unrelated to
the case currently on trial. Would the fact that a witness is currently incarcerated cause you to
automatically reject or disbelieve his testimony? å Yes å No If YES, please explain. ______________

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The defendants and several potential witnesses in this case are in most if not all cases openly gay and/or
lesbian, some of the attorneys may be as well. For this reason the parties and the Court need to inquire
into your contact, experiences and opinions regarding the Gay community and related issues.

24. Are you gay, lesbian, bisexual, transgendered or anything besides Heterosexual?
å Yes å No If YES, please indicate if you are ͞out.͟ å Yes å No

25. Are you aware of holding any negative feelings or opinions towards gay or lesbian people?
å Yes å No If YES, please explain._______________________________________

26. The defendants, Mr. Price, Ward and Zaborsky, and some potential witnesses in this case are gay
individuals. Have you, or any member of your family or close personal friend ever worked for, or been a
member of any pro-gay or anti-gay organization? å Yes å No If YES, please explain.__________________

27. Could graphic discussion of gay sexual practices, including but not limited to bondage, discipline and
Sadomasochism preclude you from being impartial? å Yes å No If YES, please explain.______________
28. Could discussion of drug use preclude you from being impartial?
å Yes å No If YES, please explain.______________

29. One of the defendants is an attorney. Could that preclude you from being impartial?
å Yes å No If YES, please explain.______________

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30. As previously noted, this case has received some media coverage. There is nothing wrong with
having heard something about this case. However, it is important that you truthfully and fully answer
the following questions concerning your knowledge about this case. Given this brief description, do you
recall having heard anything about this case? å Yes å No å Maybe Please summarize the information
you recall from any source including press coverage: __________________

31. Check to indicate whether you have heard anything about this case from any of the following
sources. (Check as many as may apply) å TV å Newspaper å Magazines å Radio å Internet å Blogs å
Books å Conversations within your own family å Conversations with friends å
Conversations with family of victim å Conversations with family of defendant å Conversations with
other people å Overheard conversations about it å Attended funeral, memorial services, vigil å Donated
money to fund for victim͛s family å Attended pre-trial or other legal proceedings å Other source of
information (please describe):__________________________________

32. How closely have you followed this case in the past? (Check one) å Very closely åSomewhat closely
åNot more than any other story in the news å Infrequently åNot at all

33. The defendants at trial are Joseph Price, Dylan Ward and Victor Zaborsky. Do you know or have you
had any contact with the defendants or their family and friends? å Yes å No å Unsure
If YES or UNSURE, please explain. _____________________________________________

34. The victim in this case is Robert E. Wone who lived in Oakton, Virginia. Did you know or have you
ever had any contact with Robert Wone or his family and friends? å Yes å No å Unsure
If YES or UNSURE, please explain. _____________________________________________

35. Possible witnesses include but are not limited to: Sarah Morgan, Scott Hixson, Michael Price, Louis
Hinton, Tom ____, John _____, Mr. William Thomas, Mrs. William Thomas, Tara Ragone, Jason
Torchinsky, and Lisa Goddard. Do you know any of them? å Yes å No If YES, please explain the nature of
the relationship(s).__________________

36. The judge who will preside over this case is D.C. Superior Court Judge Brooe Hedge.
Do you know, or have you had any contact with Judge Hedge? å Yes å No å Unsure
If YES or UNSURE, please explain. _____________________________________________

37. In this case, the Plaintiff will be represented by Attorneys Benjamin Razi and Patrick Regan.
Do you know or have you had any contact with Mr. Razi or Mr. Regan? å Yes å No å Unsure
If YES or UNSURE, please explain. _____________________________________________

38. The defendants in this case are represented by attorneys Ralph Spooner, Robert Spagnoletti, David
Schertler, Heather Nelson, Craig Roswell, Brett Buckwalter, and Larissa Byers. Do you know or have you
ever had any contact with any of them? å Yes å No å Unsure
If YES or UNSURE, please explain. _____________________________________________

39. At any time have you expressed any opinion about any aspect of this case? å Yes å No
If YES, explain what opinions you expressed. _____________________________________
40. At any time have you heard or overhead others express an opinion about any aspect of this case?
å Yes å No If YES, explain what opinions were expressed and by whom. _________________________

41. Has your exposure to information about the case including press coverage left you with any
impression about the liability of the defendants in this trial? å Yes å No å Maybe
What are those impressions? ___________________________________________________

42. This case involves alleged acts of homicide, robbery, diverse sexual orientations and drug use.
Is there anything about the nature of these charges that makes you feel that it would be difficult for you
to serve as a fair and impartial juror? å Yes å No å Maybe If YES or MAYBE, please explain. _________

43. If you sit as a juror in this case, the judge will instruct you to avoid exposure to any media coverage
or discussion about the case with your family, friends, co-workers or any other person including reading
about or researching the case on line, emailing, blogging or texting about the case. Would you find it
difficult to obey such an instruction? å Yes å No If YES, please explain.____________________________

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44. If you or anyone close to you has ever made any type of claim for damages, explain: ____________

45. If a claim for money damages has ever been made against you or anyone close to you, please explain
the circumstances. _____________

46. If you or anyone close to you has ever sued or been sued in any type of lawsuit, explain___________

47. Do you feel that money damages awarded in lawsuits are (Check one):
åExcessive å Occasionally too low åOften too large åOften too low åAbout right.

48. Do you have beliefs against awarding damages for personal injury, pain or suffering?
å Yes å No If YES, explain what opinions you expressed. ___________________________________

49. Is there anything which has not been previously asked, that you think might influence your ability to
sit as a juror and fairly decide this case? å Yes å No If YES, please explain. ________________________