SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

Criminal Division - Felony Branch

UNITED STATES :
: Criminal Case No. 2009 CF1 9230
v. : Hon. Gerald Fisher
: Trial: October 18, 2010
INGMAR GUANDIQUE :

JUROR QUESTIONNAIRE

TO THE PROSPECTIVE JUROR:

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/A” 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
know” 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 “right” or
“wrong” 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 don’t 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 – PLEASE USE ONLY DARK INK

_________________________
JUROR NUMBER
1. What is your age? _______

2. Are you: □ Male □ Female

3. Do you know or recognize any other prospective juror in this case?

□ Yes □ 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 Washington, DC? __________________

In which quadrant do you live? □ NW □ NE □ SW □ SE

5. What is your employment status? (check as many as apply)

□ Employed Full Time □ Employed Part Time

□ Unemployed □ Full time volunteer worker
□ Homemaker □ Retired
□ Disabled
□ Student (specify area of study)
□ Full time caretaker for dependent
□ 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)

□ No High School
□ Some High School
□ High School or Equivalent (GED)
□ Some College (or training, certificate programs)
□ College Degree (4 Year)
□ Post -College Training or Degree

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

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 Rock
Creek Park and especially the Western Ridge Trail, Klingle Mansion, Peirce Mill and the
Nature Center. How familiar are you with these areas of Rock Creek Park. (Check one)

□ Very Familiar □ Somewhat familiar □ Been to one or more of them once or twice

□ Don’t know them at all

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

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

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?
□ Yes □ 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?
□ Yes □ 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 such as the FBI,
DEA, US Marshall Service, Park Police, DEA, CIA, Department of Homeland Security,
TSA, ICE, INS, BATF, or any local, state or federal prosecutor’s office, or the Department of
Justice, or any correctional positions connected with a jail, a prison, or a courthouse?

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 □ Yes □ 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 Defender’s Service, the Georgetown Law Clinic, and/or the Innocence
Project?
□ Yes □ 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 victims’ rights, such as Crime Stoppers,
Orange Hats, Neighborhood Advisory Committees, or other related groups?
□ Yes □ 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 Attorney’s Office, or the agents, officers, and prosecutors who work for
those agencies? □ Yes □ 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 – or any other witness, for that matter – and must make your determination of
credibility and the weight of the officer’s 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?
□ Yes □ No

If YES, please explain: _______________________________________________________

__________________________________________________________________________
__________________________________________________________________________

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 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?
□ Yes □ 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? □ Yes □ No

If YES, please explain. _______________________________________________________

___________________________________________________________________________

23. During the course of this trial, you will hear testimony from a number of people who are
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?
□ Yes □ No

If YES, please explain. _______________________________________________________

___________________________________________________________________________

Knowledge of Gang Activity

24. Do you know anyone who has belonged to a gang or been a target or victim of gang
violence?
□ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________
___________________________________________________________________________

25. Have you or any family member or close personal friend ever participated in any anti-gang
campaign or educational program? □ Yes □ No

If YES, please explain. ________________________________________________________

___________________________________________________________________________

26. In this case you may hear testimony from witnesses who are members of a gang or former
members of a gang. Would this fact cause you to automatically reject or disbelieve his or her
testimony?
□ Yes □ No

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 If YES or UNSURE, please explain. _____________________________________________
___________________________________________________________________________

27. One of the gangs that you will hear evidence about is known as Mara Salvatrucha, or MS-13.
Have you ever heard, read or seen anything about Mara Salvatrucha/MS-13?
□ Yes □ No

a. If Yes, what have you read, seen or heard about Mara Salvatrucha/MS-13?
________________________________________________________________________
________________________________________________________________________

b. What is your opinion about people who are members or affiliated with Mara Salvatrucha/
MS-13? _________________________________________________________________
_______________________________________________________________________
_____________________________________________________________________

28. Do you believe that individuals affiliated with Mara Salvatrucha/MS-13 are likely
engaged in criminal conduct? □ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

29. Would the fact that a witness was a member, former member or affiliated with Mara
Salvatrucha/MS-13 cause you to automatically reject or disbelieve his or her testimony?

□ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

30. Some of the witnesses in this case may display extensive or visible tattoos associated with
prison gangs, or the group Mara Salvatrucha/MS-13. What is your opinion or impression of
people with extensive or visible tattoos? __________________________________________
___________________________________________________________________________

31. Would the fact that a witness had visible tattoos associated with a gang cause you to reject or
disbelieve his or her testimony? □ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

32. The defendant, Mr. Guandique has visible tattoos on his body that are associated with Mara
Salvatrucha/MS-13. Does the fact that the defendant has tattoos associated with MS-13,
cause you to form an opinion about his guilt or innocence of the charges in this case?
□ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

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Hispanic/Latino Ethnicity

The defendant and several potential witnesses in this case are of Hispanic/Latino ethnicity.
For this reason the parties and the Court need to inquire into your contact, experiences and opinions
regarding the Hispanic/Latino community and related issues.

33. Do you speak Spanish? □ Yes □ No

a. If YES, please describe how fluent you are in the Spanish language:
________________________________________________________________________

b. Do you have any training or experience as a translator of the Spanish language?

□ Yes □ No

If YES, please explain. ____________________________________________________

________________________________________________________________________

c. In this case interpreters will be used in court to translate the proceedings. When a
Spanish-speaking witness is testifying, the jurors will be able to hear the witness speak in
Spanish, which is translated into English. The court will instruct you that you must accept
the court interpreter’s translation from Spanish to English. Do you believe you would
have a difficult time accepting the translation of an interpreter if it was different than you
understood the Spanish words to mean to you? □ Yes □ No

If YES, please explain. _____________________________________________________

________________________________________________________________________

34. Are you aware of holding any negative feelings or opinions towards people of Hispanic or
Latino ethnicity? □ Yes □ No

If YES, please explain. ________________________________________________________

___________________________________________________________________________

35. The defendant, Mr. Guandique and some potential witnesses in this case are individuals who
immigrated illegally to the United States. Have you, or any member of your family or close
personal friend ever worked for, or been a member of any group or association that takes a
stand on U.S. immigration policies? □ Yes □ No

If YES, please explain. _______________________________________________________

___________________________________________________________________________

36. Are you aware of holding any negative feelings or opinions towards people who illegally
immigrated to the United States? □ Yes □ No

If YES, please explain. _______________________________________________________

___________________________________________________________________________

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Pre–trial publicity and Knowledge of the Case

37. 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?
□ Yes □ No □ Maybe

Please summarize the information you recall from any source including press coverage:
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________

38. Check to indicate whether you have heard anything about this case from any of the following
sources. (Check as many as may apply)

□ TV □ Newspaper □ Magazines
□ Radio □ Internet □ Blogs □ Books
□ Conversations within your own family
□ Conversations with friends
□ Conversations with family of victim
□ Conversations with family of defendant
□ Conversations with other people
□ Overheard conversations about it
□ Attended funeral, memorial services, vigil
□ Donated money to fund for victim’s family
□ Attended pre-trial or other legal proceedings
□ Other source of information (please describe):__________________________________

39. How closely have you followed this case in the past? (Check one)

□ Very closely
□ Somewhat closely
□ Not more than any other story in the news
□ Infrequently
□ Not at all

40. The defendant at trial is Ingmar Guandique. Do you know or have you had any contact with
the defendant, Ingmar Guandique or his family and friends? □ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

41. The victim in this case is Chandra Levy who was from Modesto, California? Did you know
or have you ever had any contact with Chandra Levy or her family and friends?
□ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

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 ___________________________________________________________________________

42. The judge who will preside over this case is D.C. Superior Court Judge Gerald Fisher. Do
you know, or have you had any contact with Judge Fisher? □ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

43. In this case, the government will be represented by Assistant U.S. Attorneys Amanda Haines
and Fernando Campoamor, who are prosecutors from the Office of the United States
Attorney in the District of Columbia. Do you know or have you had any contact with Ms.
Haines or Mr. Campoamor? □ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

44. Have you or any family member had any dealings with Office of the United States Attorney?
□ Yes □ No

If YES, please explain. _______________________________________________________

___________________________________________________________________________

45. The defendant in this case, Mr. Guandique, is represented by Santha Sonenberg and Maria
Hawilo, who are defense attorneys with the Public Defender Service for the District of
Columbia. Do you know or have you ever had any contact with Ms. Sonenberg, or Ms.
Hawilo? □ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

46. Have you or any family member had any dealing with the Public Defenders Service for the
District of Columbia? □ Yes □ No

If YES, please explain. ________________________________________________________

___________________________________________________________________________

47. At any time have you expressed any opinion about any aspect of this case? □ Yes □ No

If YES, explain what opinions you expressed. _____________________________________

___________________________________________________________________________
___________________________________________________________________________

48. At any time have you heard or overhead others express an opinion about any aspect of this
case?
□ Yes □ No

If YES, explain what opinions were expressed and by whom. _________________________

___________________________________________________________________________
___________________________________________________________________________

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49. Has your exposure to information about the case including press coverage left you with any
impression about the guilt or innocence of the defendant, Mr. Guandique?
□ Yes □ No □ Maybe

What are those impressions? ___________________________________________________

___________________________________________________________________________
___________________________________________________________________________

50. This case involves alleged acts of murder, robbery, sexual assault, kidnapping, and gang
affiliation. 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?

□ Yes □ No □ Maybe

If YES or MAYBE, please explain. _____________________________________________

__________________________________________________________________________
__________________________________________________________________________

51. Our legal system provides that: (1) when a person is brought to court charged with a crime,
that person is presumed innocent unless and until the government presents evidence that
convinces you of guilt beyond a reasonable doubt; (2) the government has the burden of
proving the defendant guilty beyond a reasonable doubt; (3) neither the defendant nor his
attorney has any responsibility to prove the defendant innocent, and (4) because the
defendant is presumed innocent, he need not testify nor offer any evidence, and the jury is not
permitted to conclude that the defendant is guilty because he decides not to testify or present
any evidence. Do you have any hesitancy in following and applying each and every one of
these instructions?

□ Yes □ No

If YES, please explain ________________________________________________________

___________________________________________________________________________

52. You may hear testimony from two women who individually were assaulted while jogging in
Rock Creek Park in 2001 and identified Mr. Guandique as the person who assaulted them.
The law prohibits you from convicting Mr. Guandique because you believe he is a bad person
or has a bad character. Consequently, the law only permits you to use the evidence of the
two prior incidents to prove that Mr. Guandique committed the crimes charged in this case if
you find that the circumstances of the other offenses and those charged in this case are so
similar that it is likely that the same person who committed the prior offenses committed
the offenses charged in this case. Would you have any difficulty in applying this
principle of law?

□ Yes □ No □ Unsure

If YES or UNSURE, please explain. _____________________________________________

___________________________________________________________________________

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53. 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? □ Yes □ No

If YES, please explain. ________________________________________________________

__________________________________________________________________________

54. 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? □ Yes □ No

If YES, please explain. _______________________________________________________

___________________________________________________________________________

55. Before you begin answering the other questions in this questionnaire, the attorneys for the
government and the defense are going to read a list of names of people who may be called as
witnesses or who may be mentioned in testimony during trial. If you are familiar with any of
these individuals, please write his/her name below, and after the name indicate the
relationship that your or any family member or close personal friends may have with this
person. If you do not know anyone on the list, write “none” in the space provided here:

___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________

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