Jury selection questionnaire for Roeder's trial

IN THE EIGHTEENTH JUDICIAL DISTRICT
DISTRICT COURT, SEDGWICK COUNTY, KANSAS
CRIMINAL DEPARTMENT

THE STATE OF KANSAS,
Plaintiff,

vs.

SCOTT P. ROEDER.
Defendant.

Case No.09CR1462

JURY QUESTIONNAIRE


INTRODUCTORY COMMENTS

Thank you for meeting your responsibilities of citizenship by being here today.
The purpose of taking your time today is to look at your qualifications to be a juror in your
court system. There will be no right or wrong answers to the questionnaire. The only right answers are complete and honest responses to all questions. The purpose of using this questionnaireis three-fold.

The first is to gain full and honest responses from you without revealing that information to the entire panel of jurors in open court. This will protect the confidentially of your responses. Second, the questionnaire will spare you the long wait that usually occurs when the attorneys must repetitiously ask all of you the same questions. Finally, the use of this questionnaire provides each side the opportunity to select a fair and impartial jury. Therefore, you full cooperation is of the greatest significance to the administration of justice in the case.

The answers you give to the questions here are under a penalty of perjury. Each answer must
be true and correct to the best of your knowledge, information and belief. Complete answers will save the Court and all parties involved a great deal of time.

You must not discuss the questions or your answers with anyone before, during or after the
completion of the questionnaire.T his includes all family and friends. Do not assume that answers
given will qualify or disqualify you, from jury service. Please print or write legibly. Answer honestly.

If a question goes to something that is not applicable to you, write N/A in the space provided
for an answer. If you do not know the answer, write DO NOT KNOW. If you need more space to
write your answer, please do so on the extra sheets attached to the questionnaire. Be sure to write the number of the question that you are answering on the blank sheet. If you do not understand the question, just write DO NOT UNDERSTAND.

The completed questionnaire will become part of the court's records. The judge, the lawyers
and the parties all examine the records. The attorneys are under orders to maintain the confidentiality of any information they learn in the course of reviewing these questionnaires.
One's past experience viewed in light of the facts of the case is the best measure of one's
qualifications to serve as a juror in a particular case. By this questionnaire, we shall look into your personal experiences, your "court" type experiences, any "law enforcement" type experiences that you may have had and any experience that you have had similar to the case to be tried.

Plaintiff and Defendant are legal words. Plaintiff means the person or entity that brings a
lawsuit. Defendant means the person or entity that a lawsuit is brought against. The State of Kansas is the plaintiff, and brings the lawsuit here. The plaintiff-state claims that the defendant has violated the laws of the State. The defendant denies the State's claim.

It is the law that the claims of the State must be proved beyond a reasonable doubt because the
defendant is protected by a rule of law called the presumption of innocence. That rule means that anyone accused of a crime is presumed to be innocent of that crime. This presumption of innocence protects an accused at the time the State files a case. It stays with a defendant all through the case unless the jury finds guilt beyond a reasonable doubt. Such a finding by a jury must be based upon the evidence presented in court and the law of the case as explained by the judge. It must never be based upon bias or prejudice or influences outside the evidence and law of the case.


Here summarized are the claims of the State:

In the Complaint/Information, the prosecution alleges that on or about the 31st day of May,
2009, in Sedgwick County, Kansas, Scott P. Roeder unlawfully, intentionally and with premeditation killed George R. Tiller.

In the Complaint/Information, the prosecution alleges that on or about the 31st day of May,
2009, in Sedgwick County, Kansas, Scott P. Roeder unlawfully and intentionally placed another
person, to-wit: Gary L. Hoepner, in reasonable apprehension of immediate bodily harm, with a deadly weapon, to-wit: a handgun.

In the Complain/Information, the prosecution alleges that on or about the 31st day of May,
2009, in Sedgwick County, Kansas, Scott P. Roeder did then and there unlawfully and intentionally placed another person, to-wit: Keith E. Martin, in reasonable apprehension of immediate bodily harm, with a deadly weapon, to-wit: a handgun.

QUALIFICATIONS

To be selected to serve on a jury one must meet the following qualifications:

(Please answer yes or no)
1 Are you at least 18 years of age?
2. Are you a resident of Sedgwick County?
3. Are you a resident of the State of Kansas?
4. Are you a citizen of the United States of America?
5. Are you able to read, write and understand the English language?
6. Have you been adjudged guilty, pleaded guilty or no contest to a felony crime within
the last ten (10) years?
7. Have you been found incompetent by a judge?
8. Have you served as a juror in the county within one year?

GENERAL BACKGROUND

9. Name/Maiden Name
10. Age
11. Race
12. Place of birth
13. Street Address
Nearest Major Intersection
14. How long have you lived at your current address?
15. How long have you lived in Sedgwick County, Kansas?
16. Do you own or rent your home? Yes _ No_ ; If neither, please explain.
17. What is the highest level of education completed?
Less than High School
High School Graduate
Vocational/Technical
Business school
Secretarial Paralegal
Community College: I year _2 years _ 3 years _
Name and location:
Four year college_
Name, location, and number of years completed, degrees received, if any.
Post-graduate
Name, location and number of years completed:

EMPLOYMENT

18. Do you work outside the home? Yes No
If yes, where:
Please list specific duties:
How long have you been with your present employer?
19. Have you had any previous occupations? Yes _No
If yes, please list all employers, dates of employment, titles and responsibilities:
20. If employed, will you be paid by your employer while on jury duty? Yes _ No
21. Will jury duty cause you any undue financial hardship?
If yes, please explain:

SOCIAL/CIVIC BACKGROUND

22. Do you belong to any civic or social organizations? Yes - No
If yes, please explain and describe:
23. Do you do any type of volunteer work? Yes -No
If yes, please explain:
24. What are your hobbies or interest outside of work and family?
25. Have you any connection to groups that lobby for changes in the law? Yes - No
If you do, what group and what part do you play in the lobbying efforts?

MARITAL STATUS

26. Please check the following that apply:
Single- Married- Separated-Widowed-Divorced-Living with non-marital mate
27. If married or with mate, for how long?
28. If your spouse or mate is employed, please describe what type of work they do, including
name and location of employer, and length of time at the position:
29.If your spouse or mate is retired, presently unemployed or disabled, please address the
requested information above for the last job he/she held.

CHILDREN

30. If applicable, please list the names, ages and gender of your children .
Name
Age
Male?Female
31. If applicable, please list the highest education level and occupation of your children.

RELIGION

32. What is your religious affiliation/denomination, if any?
33. Do you attend a place of worship; i.e., Church, Temple, etc? Yes No
If yes, please state where and how often:
34. If applicable do you participate in other activities in your place of worship?
Yes
No
If yes, please state the type of activities and how frequently:

35. If married or living with a mate, please describe their religious preference:
36. If applicable, does your place of worship and/or particular denomination take an official
stand on the practice of abortion?
Yes
No
Unsure
37. How would you rate the importance of your religious beliefs in your day to day life?
Utmost Important
Very important
Somewhat important
Not important at all
38. Do you have any principles based on religious or ethical teaching or dogma that would
affect your ability to serve as a fair and impartial juror?
Yes
No
If yes, please explain:

MILITARY SERVICE

39. Have you ever served in the military?
Yes
No
If yes,
When:
Where:
Branch:
Highest Rank:
Your duties:
Type of discharge and when:
Were you ever engaged in combat?
Yes
No
Were you ever involved in a military court martial?
Yes
No
If yes, explain:

FIREARMS

40. Have you ever fired a handgun or rifle? Yes _ No _
41. Are you or a member of your immediate family a past or present member of the National Rifle Association?
Yes
No
If yes, please indicate who and during what period of time.
42.Have you specialized knowledge of the use, operation or identification of firearms?
Yes
No
If so, what is the source of this knowledge?

Do you feel that you are qualified as a firearms expert based on your specialized knowledge?
43. Do you now or have you ever owned firearms?
Yes
No
If you own guns currently, what use is made of the guns? i.e. hunting, collecting, protection,
etc.
Do you shoot on a regular basis?

HEALTH

44. Do you have any specific health problem of a serious nature that might make it difficult or
uncomfortable for you to sit as a juror in this case? Yes No
If yes, please explain:
45. Are you taking medication regularly that might make it difficult for you to pay attention or
concentrate for long periods of time? Yes No
If yes, please explain:

WITNESS EXPERIENCE

46.Have you ever testified as a witness in a criminal or civil case?
Yes
No
If yes, please explain:

COURT EXPERIENCE

47. Have you, a friend, a relative, or anyone you know ever been arrested for or convicted of a
felony?
Yes
No
If yes, please explain:

48. Have you ever been a party to a lawsuit or filed a claim against a governmental agency?
Yes
No
If yes, please explain:

VICTIM EXPERIENCE

49. Have you, or any member of your family, or a close friend ever been a victim of a crime?
Yes
No
lf yes, please explain:

50. Have you, a friend, a relative, or anyone you know been seriously injured or killed as a result
of criminal conduct?
Yes
No
If yes, please explain:

If yes, please explain how that experience affected your feelings about the criminal justice system.

ADMINISTRATION OF JUSTICE

51. Have you, any member of your family, or a close friend ever taken a course in administration
of justice, or studied law?
Yes
No
If yes, please explain:

52. Have you, any member of your family or a close friend ever been affiliated with any of the
following?
Law Enforcement (police officer, Sheriff, F.B.I., etc) -
Corrections( Prison Guard, Jailer, Warden, etc)-
Security Employment
Mental Institution
Juvenile Facilities
Probation or Parole
District Attorney, United States Attorney, or other prosecutor
Public Defender or Private Defense Counsel
Law School
Investigative work
Immigration Services
Drug Enforcement Administration
Please explain the ones you've checked.

53. Looking at all the experience that you have had with law enforcement, is there anything
about your experience that has created in you a bias for or against law enforcement that
might affect your ability to fairly evaluate the evidence that comes into the case through a
law enforcement officer, should you be chosen to serve in the case?
Yes
No
If yes, please explain

54. Is there a crime prevention group in your neighborhood?
Yes
No
If so, do you participate in the group?

55. Do you perceive there to be any problems in the current operation of the
criminal justice system?
Yes
No
If yes, please elaborate on your answer:

56. Do you know of any reason that would prevent you from following the law that the judge says
applies to this case?
Yes
No
If yes, what is the reason?

SPECIAL STUDIES

57. Do you have experience in the gathering, maintaining, preserving, preparation or analysis of
specimens for forensic purpose? This would be tool marks, fingerprints, hair, blood, saliva,
bullets, shell casings, drugs etc. Yes - No
If you have such experience please tell us the details.
58. Do you have specialized knowledge of DNA science?
Yes
No
If you do, tell us the source of this specialized knowledge.

59. Do you have experience in the study of or the application of law?
Yes
No
If you do, tell us about that experience?
60. Have you had training, education or experience in psychiatry or psychology?
Yes
No
If yes, please tell us of your training, education or experience.

PRIOR JURY SERVICE

61 . Have you ever been called for jury duty prior to this action? Yes - No
If yes, please explain when, where, and what type of case you heard.


Were you able to reach a verdict? Yes No
Were you the jury foreperson Yes
No
Tell us if you view your prior service in a positive neutral or negative manner?
Please explain.
Did you talk to the Judge, or the attorneys after the case was over, and learn of additional
information that was not presented at trial? Yes No
If so, please explain.

NEWS SOURCES

62. Do you read a newspaper on a regular basis, i.e., three or more times per week?
Yes
No
If yes, please list which newspaper(s) you regularly read:
Wichita Eagle
USA Today
Wall Street Journal
Kansas City Star
Other Please describe:

63. Do you subscribe to the newspaper or do you purchase the paper with each reading or do
you read someone lse's copy?
Subscribe
Purchase
Read someone else's copy
64.Do you or anyone in your immediate household have a subscription to any weekly or monthly
magazines or newsletters?
Yes
No
If yes, please list all magazines and length of time receiving the subscription.



65. How often, if ever, do you watch the local television news?
Never
Occasionally_
Regularly
Nightly
If you answered occasionally, regularly or nightly please disclose what local station's news
programs you watch. Channel(s) __6:00 __10:00
66. Please list any and all national or syndicated news programs you watch, including such
programs as network news,48 hours, Hard Copy, etc.
67. Please disclose any and all news channels you watch. (one or more times a week)
CNN
Headline News
Fox News
CBN
CBS
ABC
NBC
MSNBC
Other
68. Do you receive any of your news information from Internet Sites: Yes No
Ifyes, please provide details such as source and frequency
69. Do you believe there is an ideological bias in the various news sources?
Yes
No
If so, how?

CASE AT HAND

70. Are you now or were you personally acquainted with George Tiller or a family member of
George Tiller?
Yes
No
If yes, please print the name here and tell us about your relationship with the person.
71. Are you now or were you personally acquainted with Gary L. Hoepner or a family member of
Gary L. Hoepner? Yes
No
If yes, please print the name here and tell us about your relationship with the person.

72. Are you now or were you personally acquainted with Keith E. Martin or a family member of
Keith E. Martin?
Yes
No
If yes, please print the name here and tell us about your relationship with the person.

73. Are you personally acquainted with defendant, Scott P. Roeder, or any family member or
friend of his?
Yes
No
If you are, please print the name of such person here and tell us about your relationship with
the person.

74.Here are the names of the lawyers in the case. Please circle the name of anyone known to you
personally and tell us of your relationship with that lawyer.
Nola T. Foulston
Kim T. Parker
Ann Swegle
Mark Rudy
Steve Osburn
75. A list is attached containing the names of people who may be called as witnesses in this case.
Please review the list. Circle the name of any witness you know or think you might know.
Then write the name here and tell us about your relationship with the person.

MEDIA

Most people here today know something about the facts of this case. The purpose of the next
few questions is to look at what you know about this case.
If you are a witness in the case because of what you know about the facts, you would be
disqualified to be a member of the jury.
If your knowledge of the facts comes from what you have heard or seen or read in news reports
or in some political advertisement, commentaries or editorials, you are not disqualified for jury
duty.
76.Prior to the date of Dr. George Tiller's death (May 3I,2009), had you ever heard of Dr.
Tiller, either through the media, political publications, word of mouth, or otherwise?
Yes
No
lf yes, please explain:

77. After the death of Dr. George Tiller, to what degree did you follow the events of his demise
and the subsequent arrest of the defendant?
Not at all, do not know anything about the case
Causally, not sure of any facts or surrounding circumstances
Mildly interested, read the "headlines," have knowledge of the facts
Closely, I read the stories atd/or watched the news, know the facts pretty well
Intensely, I followed the case as closely as I could
None of the above
Please explain further:

78. What,if any, information have you learned throught he media or other sources regardingt he
defendant in this case Scott Roeder? Please be a specific as possible.
79. Do you have any knowledge, other than from the print or electronic media, about the facts and circumstances surrounding this case?
Yes
No
If yes, please explain in detail:

80. Since the death of Dr. George Tiller have you had any conversations with anyone regarding the facts and circumstances suffounding this case?
Yes
No
If yes, please explain:

81. Have you seen, lead or heard news reports of this case?
Yes
No
If yes, please list the source as best you recall (newspaper television, radio, etc.).
82. Have you heard, seen or read about this case being used in a political advertisement,
commentary or editorial?
Yes
No
If yes, tell us the source and message attempted to be conveyed, as best you can recall.
83. If you have formed opinions based on information drawn from neu,'s reports and/or political
advertisements commentaries or editorials, is your opinion on the question of innocence or
guilt of the accused so set in your mind that you could not set the opinion aside in deference to
the law? Yes
No
84. Should you be chosen to serve in this case, would you base your verdict on the evidence
presented in court and the instructions of law given you by the judge rather than on information
you remember from news reports or political advertisements, commentaries or editorials?
Yes
No
If yes, please explain:
85. It is anticipated that there will be both both local and national coverage of the trial in a gavel to gavel fashion. If selected as a juror on this case, would the scrutiny of the trial and the
accompanying pressure in any way cause you to feel concerned or compromised in the
fulfillment of your duties?
Yes
No
If yes, please explain:

ABORTION

86. What are your personal opinions on abortion?

GENERAL

87. Do you hold any beliefs that would prevent you from following the law of the State of
Kansas and the instructions of the court?
Yes
No
If so, please explain.
88. Are there any other topics, other than those addressed in the various questions listed above,
that you feel need to be brought to the Court's attention relative to your ability to serve as a
fair and impartial juror in this case?
Yes
No
If yes, please explain:

AFFIRMATION:

I deciare under the pains and penalties of perjury, that the answers and information given by me on this questionnaire are true to the best of my information, knowledge and belief'
Date:
Signature:
Print Name