Special counsel Robert Mueller's team wants to use a written questionnaire to gauge whether “widespread media attention” has biased potential jurors for former Trump campaign chairman Paul Manafort’s upcoming criminal trial.

The lead Russia investigator filed an eight-page motion on Thursday raising concerns about how both his overall probe into Trump’s 2016 presidential campaign and Moscow election meddling, as well as the Manafort case specifically, had generated extensive media coverage — not all of it correct — that could taint the jury pool. Manafort is facing a series of financial fraud, tax and lobbying charges in cases spiraling out of Mueller’s broader probe.


“The reporting, at times inaccurately, comments on the nature of the evidence collected in the case or activities of the parties,” Andrew Weissmann, one of Mueller’s lead prosecutors, wrote, noting it had found thousands of references to the investigation in its search of newspaper, television and radio coverage.

“Furthermore, the amount of publicity about this case is only likely to grow as the trial date approaches, and such publicity increases the possibility that jurors will form biases or pre-formed opinions that may prejudice one or both parties,” Weissmann added.

To help pick jurors for a possible three-week trial in Alexandria, Virginia, Mueller’s team provided a list of 52 potential questions seeking more information about the jurors, including whether they’d “seen, read, or heard anything at all about this case in any form of media, including newspaper, television, radio or internet.”

If a potential juror checks the yes box, they’re asked to explain what they’ve seen and the “source of that information.”


The questionnaire also asks potential jurors to explain any personal ties with law enforcement and the IRS. Separately, it probes whether the person has opinions about hearing from witnesses who may be “individuals who were involved in crimes themselves” and may testify “pursuant to a cooperation agreement with the government or an immunity order.”

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Earlier this year, Manafort's business partner Rick Gates, who was also a Trump campaign aide, agreed to a plea deal that saw Mueller drop the charges against him in exchange for his cooperation.

Previewing the Manafort trial ahead, Mueller’s questionnaire asks possible jurors whether they already have opinions about crimes including bank fraud, filing false tax returns and failing to report foreign bank accounts, as well as whether they have any ties to Ukraine — issues related to Manafort’s charges.

Mueller himself is the topic of one suggested question to jurors, which asks: “In this case, the United States is represented by the United States Department of Justice through Special Counsel Robert S. Mueller, III. Is there anything regarding the Special Counsel’s Office that would prevent or hinder you in any way from rendering a fair and impartial verdict in this case based solely on the evidence presented and the Court’s instructions on the law?”


Manafort has pleaded not guilty to all of Mueller’s charges, which are set to go to trial in two different federal venues, first in Northern Virginia on July 25, then in a separate case in Washington, D.C., on Sept. 17.

The former Trump campaign chairman and longtime GOP operative was placed under house arrest after his initial indictment last October. But he was jailed Friday after prosecutors claimed he attempted to tamper with the testimony of two potential witnesses in the Washington case.

Outside of its court pleadings, Mueller’s team has avoided much of anything in the way of public comment about its overall Russia investigation. In its motion Thursday, however, the team made clear it had been following the extensive media coverage disparaging both Mueller’s office and Manafort.

“Some of the media accounts question the legitimacy of the Special Counsel’s investigation, tending to advance the opinion that the investigation is ‘tainted’ and therefore its results are suspect. Other media accounts, by contrast, include disparaging descriptions of the defendant,” Weissmann wrote.

A Manafort spokesman declined comment.