The Government submitted i ts proposed jury questionnaire to the court on April 2, 2019. Keith Raniere, Clare Bronfman, Allison Mack, and Kathy Russell have in substance agreed to the questions. As ordered by Judge Nicholas G. Garaufis, the questionnaires will be ready for 500 potential jurors to fill out on Monday, April 8, 2019. The names of potential jurors and selected jurors will apparently be shielded until after the trial is over. Additional precautions may be taken to shield jurors’ names until after the trial. The prosecution is estimating the trial will last 8-10 weeks. So, if it starts on time, we should have a verdict by mid-July. The prosecution has renamed the case to include Raniere’s titles of “Master” and “Grandmaster” – just in time for the jury questionnaire.

The case is now officially called

UNITED STATES OF AMERICA

-v- KEITH RANIERE,

also known as “Vanguard,”

“Grandmaster,” and

“Master,”

CLARE BRONFMAN,

ALLISON MACK,

KATHY RUSSELL and

LAUREN SALZMAN,

Defendants.

Case no: 18 CR 204 (S-2) (NGG)

***

According to the jury questionnaire, there may be evidence introduced about the following topics:

– Abortions;

– Self-help programs;

– Scientology, Landmark Forum, etc.;

– Multiple sexual partners;

– Sexually explicit images and language;

– Secret societies, rituals, and cults;

– Illegal immigrants;

– Rich people;

– People who didn’t pay taxes; and

– People who have had “body modifications” (such as tattoos and brandings).

Here’s a list of the feds who have worked on this case:

(i) Assistant United States Attorney Moira Penza

(ii) Assistant United States Attorney Tanya Hajjar

(iii) Assistant United States Attorney Mark J. Lesko

(iv) Assistant United States Attorney Kevin Trowel

(v) Assistant United States Attorney Karin Orenstein

(vi) Paralegal Specialist Teri Carby

(vii) Michael Weniger, Special Agent, FBI

(viii) Michael Lever, Special Agent, FBI

(ix) Delise Jeffrey, Special Agent, FBI

(x) Charles Fontanelli, Task Force Officer, FBI/New York State Police

(xi) Megan Buckley, Special Agent, Homeland Security Investigations

(xii) Christopher Munster, Special Agent, Homeland Security Investigations

(xiii) Richard Guerci, Investigator, U.S. Attorney’s Office

(xiv) Kathleen Fiato, Special Agent, IRS

(xv) Patrick Griffee, Special Agent, IRS

Here is the list of defense attorneys who will be on the case [barring plea deals]

(i) Marc Agnifilo, Esq.

(ii) Teny Geragos, Esq.

(iii) Paul DerOhannesian, Esq.

(iv) Danielle Smith, Esq.

(v) Mark Geragos, Esq.

(vi) Kathleen Cassidy, Esq.

(vii) Alexandra Shapiro, Esq.

(viii) Fabian Thayamballi, Esq.

(ix) Justine Harris, Esq.

(x) Amanda Ravich, Esq.

(xi) William McGovern, Esq.

(xii) Sean Buckley, Esq.

(xiii) Matthew Menchel, Esq.

*****

Here’s an interesting paragraph:

Here’s a very interesting question from the Jury Questionnaire:

“Some government witnesses may testify that they participated in serious crimes themselves including forced labor and identity theft. These witnesses, who may be referred to during trial as “cooperating witnesses,” may have pleaded guilty to crimes and may be testifying pursuant to agreements with the government in hopes that their own sentences will be reduced. Do you have any opinions or beliefs about cooperating witnesses who are seeking a reduced sentence that would make it difficult for you to be fair and impartial in considering their testimony?”

***

In total, there are 87 questions on the proposed jury questionnaire. Many of them are standard questions likely asked of jurors on criminal cases.

But some are specific to this case. These questions reveal a lot – including the probable direction the prosecution will take on the case:

32. Have you or anyone close to you ever participated in any self-help programs or read any

self-help books?

Yes (self) _______ Yes (other) _______ No _______

If yes, please state which program(s)/book(s) and describe your (or the other person’s)

experience?

_____________________________________________________________________

_____________________________________________________________________

If yes as to you, what did you hope to get out of the experience?

_____________________________________________________________________

_____________________________________________________________________

33. Have you or anyone close to you ever taken any Scientology courses?

Yes (self) _______ Yes (other) _______ No _______

If yes, please describe your (or the other person’s) experience?

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

34. Have you or anyone close to you ever participated in a Landmark Forum, EST or anything

you view as similar?

Yes (self) _______ Yes (other) _______ No _______

If yes, please describe your (or the other person’s) experience?

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

35. There may be evidence in this case about people engaging in relationships with multiple

sexual partners. Would hearing about that type of evidence affect your ability to serve as

a fair and impartial juror in this case?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

36. There may be evidence in this case about abortions. Would hearing about that type of

evidence affect your ability to serve as a fair and impartial juror in this case?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

____________________________________________________________

37. There may be evidence in this case that includes sexually explicit images and language.

Would hearing about that type of evidence affect your ability to serve as a fair and impartial

juror in this case?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

38. There may be evidence in this case about fraternities, sororities, secret societies, rituals, or

cults. Would hearing about that type of evidence affect your ability to serve as a fair and

impartial juror in this case?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

39. There may be evidence in this case about people who were in the United States illegally.

Do you have any opinions regarding illegal immigration that would affect your ability to

serve as a fair and impartial juror in this case?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

40. There may be evidence in this case about rich individuals. Do you have any opinions

regarding rich individuals that would affect your ability to serve as a fair and impartial

juror in this case?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

41. There may be evidence in this case about people who did not pay taxes. Do you have any

opinions regarding people who do not pay taxes that would affect your ability to serve as

a fair and impartial juror in this case?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

42. There may be evidence in this case about skin modifications (such as tattoos and branding).

(a) Do you have any body modifications?

Yes _______ No _______

If yes, please describe.

_______________________________________________________________

_______________________________________________________________

(b) Would hearing about evidence of body modifications affect your ability to serve as a

fair and impartial juror in this case?

Yes _______ No _______

If yes, please explain.

_____________________

44. Are you now, or have you ever been, a registered sex offender or ordered by a court to

register as a sex offender?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

45. Have you or has anyone close to you ever sought treatment (court-ordered or otherwise)

for sex addiction or sexual deviance?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

46. Is anyone close to you a registered sex offender?

Yes _______ No _______

If yes, please explain who and the circumstances?

_______________________________________________________________

_______________________________________________________________

If yes, do you believe his/her designation as a sex offender is unfair?

______________

47. Have you or anyone close to you ever been the victim of incest, child molestation, or child

abuse?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

48. Have you or anyone close to you ever been the victim of sexual assault, including date

rape?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

49. If you answered yes to question 47 or 48, do you believe that would affect your ability to

serve as a fair and impartial juror?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

50. Have you ever known anyone who you believe was falsely accused of sexual abuse or

sexual assault of a minor or an adult?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

51. Do you worry about you or someone close to you being falsely accused of sexual abuse or

sexual assault?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

52. If you answered yes to question 50 or 51, do you believe that would affect your ability to

serve as a fair and impartial juror?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

53. Do you believe that people under seventeen should be able to consent to sex with adults?

Yes _______ No _______

If yes, please explain.

_______________________________________________________________

_______________________________________________________________

54. Have you heard of the “#MeToo” movement?

Yes _______ No _______

If yes, what is your opinion of the “#MeToo” movement?

_______________________________________________________________

_______________________________________________________________

67. This case is likely to receive ongoing media attention. The Court wants to make sure that

this case is decided solely on the evidence presented in the courtroom and not based on

influences outside the courtroom. The Court will be advising you daily that you must avoid

reading about the Case on the Internet, in newspapers or listening to any radio or television

reports about the case. The Court will further advise you not to discuss the case with family

or friends during the trial or with your fellow jurors until it is time to deliberate. Would

these restrictions pose any difficulty for you?

Yes __________ No __________

If yes, please explain: ______________________________________________________

________________________________________________________________________

68. The charges in this case involve allegations of, among other things, sex trafficking, forced

labor, child pornography and child exploitation. Is there anything about the nature of these

allegations that would make it difficult for you to be fair and impartial?

Yes __________ No __________

If yes, please explain: __________________

78. You may hear testimony from certain individuals that the government alleges are victims.

A victim’s testimony is not to be given any more or less credence than any other witness’s

testimony, just because that person is an alleged victim. Do you have any opinions or

beliefs about alleged victims that would make it difficult for you to be fair and impartial in

considering their testimony?

Yes ________ No ________

If yes, please explain: ______________________________________________________

__________________________________________________________________

79. Some government witnesses may testify that they participated in serious crimes themselves

including forced labor and identity theft. These witnesses, who may be referred to during

trial as “cooperating witnesses,” may have pleaded guilty to crimes and may be testifying

pursuant to agreements with the government in hopes that their own sentences will be

reduced. Do you have any opinions or beliefs about cooperating witnesses who are seeking

a reduced sentence that would make it difficult for you to be fair and impartial in

considering their testimony?

Yes _______ No _______

If yes, please explain:

________________________________________________

______________________

***

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