Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 1 of 36 PageID #: 977

EXHIBIT A

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 2 of 36 PageID #: 978

Juror #58 4(g). The juror worked as a clerk in a grocery store in Portland. Did the juror grow up in Portland? 4(k). Where did the juror live in the Bronx? How long did the juror live there? 17. What role does the juror play in the organizations that he belongs to? 36. What was the jurors involvement in volunteer groups? What was the jurors involvement in Teach for America? 39. What does the jury mean with his answer to question 59?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 3 of 36 PageID #: 979

Juror #59 4. What type of foundation does the juror work for? 34(b). The Juror cannot say for certain if he could set aside personal feelings. 4(i). Who does the jurors fianc work for? 4(j). Where did the juror live previously? 19. What type of websites does the juror receive her news from? *34. The juror is not sure whether she could set her feelings aside. 39. Would the jurors feelings affect her ability to be fair?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 4 of 36 PageID #: 980

Juror #60 What neighborhood in Brooklyn does the juror live in? 4(f). In the jurors supervisory role, did she ever have to write up employees for problems? 4(g). Is the juror in charge of compliance? 4(i). What did the jurors husband use to do? *35. What does the juror remember about the Espadas? Can the juror put aside whatever he heard and decide this case based solely on the evidence at trial and the law as instructed by the Court?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 5 of 36 PageID #: 981

Juror # 62 4(e). Please further explain the jurors position as a in-home sales person who supervises 20 people. 7. What does the juror mean by his father manages money? Does the juror pay his own expenses? Does the juror file his own tax returns? 10(b). Please elaborate on how they jurors employer providing a credit card but not providing an expense account. 30. What was the juror investigated for at work?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 6 of 36 PageID #: 982

Juror #63 *4e. What agencies do you monitor? *4f. When you say evaluate and close down agencies, what do you do? There will be testimony from people who work for HRSA and other federal agencies about Soundview and their evaluations of Soundview. Would your experience in your job affect your ability to evaluate this testimony fairly for both sides? *4g. When you say that you audit "tiny" agencies, what is the size of these agencies? What does your evaluation involve? *4i. What is your wife the Deputy Executive Director of? *10a. Where do you travel for your business and how often? Do you get your expenses reimbursed? Do you have a per diem? *35. What has he heard about Espada? Where? Did he hear anything through his job? Can the juror put aside whatever he heard and decide this case based solely on the evidence at trial and the law as instructed by the Court? 36. What has he done for the Training Institute for Mental Health?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 7 of 36 PageID #: 983

Juror #65 7. What does his stepmother do? 9. Where is he a student? 15. When his mother worked in a lawyers office, what did she do? 34. What are his opinions about politicians?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 8 of 36 PageID #: 984

Juror #66 4(b). What is a technical representative of a manufacturer of waterproofing productions? 4(h). Who home schools his children? 4(i). What is his spouses job? What was her previous job? 4(j). Where has be previously lived? 21. What internet sites does he visit?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 9 of 36 PageID #: 985

Juror #67 1. Please clarify the answer to whether jury duty would be a hardship. 4(k). Did he grow up in the Bronx? If so, where? 26. Did he have to testify in his lawsuit?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 10 of 36 PageID #: 986

Juror #68 4(c). In his answer to the occupation question, he stated that he is the Production Assistant for MLB.com but he has only been working at his new job for one day. Please explain. 4(g). There will be testimony at the trial that janitors who worked for a company owned by the defendant were paid a low amount. Will his personal past experience working as a janitorial/maintenance worker affect his opinion of the defendants in a way that would interfere with him evaluating the evidence in this case fairly? 12. He has a cousin who works in the DA's office. Would this cause him to be biased in favor of the prosecution in any way? 14. There will be testimony about billing and coding in this case. Will his personal experiences affect his ability to listen to the evidence and decide this case based on the evidence presented at trial and the law as the Court will instruct him? *38-39. The juror has very strong opinions regarding tax laws and laws regarding theft from notfor-profits that receive government funds. Could he put those opinions aside and be fair to both sides? Would those opinions cause him to lower the standard of proof for the government?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 11 of 36 PageID #: 987

Juror #69 2. Would anyone else be able to care for her husband? She says the mother in law is also a caretaker - would she be able to do this? 4(a). At what kind of company does the juror work? 4(i). What was her husbands occupation? 4(j). Where has she lived in the past?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 12 of 36 PageID #: 988

Juror #70 - Excuse for Cause/Hardship, Juror says she will not be paid after 4 days *1. Juror says she will not be paid a salary after 4 days and she supports herself. 4. Where has she worked before becoming a social worker? *11. Will her familys work in law enforcement affect her opinions in this case? Will she give greater weight to law enforcement testimony? *17. What was her involvement in the National Organization of Social Workers? *34-35. The juror responded that she knew about Espadas actions in the senate and that she believed that Espada and his son extorted money. Could she set aside anything she has learned from the press and decide this case solely upon the evidence presented at trial and the instructions on the law? *39. The juror has strong opinions about laws regarding theft from a not-for-profit that receives government funds. Would these opinions cause her to be biased or to hold the government to a lower standard of proof? *40. The juror responded that she would have difficulty avoiding media coverage of this case. Could she be fair?

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Juror #72 Which neighborhood of Queens does the juror live in?

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Juror #74 4(e). The juror responded that he was the gang foreman. Please explain. *4(g). The juror responded that he was a federal inspector at LIRR. Please explain. *34. The juror responded that he believes there is a lot of shenanigans with fundraising and donations. Please explain. Would this opinion cause him to be biased against the defendants?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 15 of 36 PageID #: 991

Juror #77 - Cause/Hardship, the juror has a special needs child and the Juror believes that the defendants should testify *1. The juror responded that she needs to care for her child, making it difficult to serve on the jury. Would this interfere with her ability to serve on the jury? *39. The jurors response to question 39 was unclear. What views does she have regarding laws against the theft of money from a not-for-profit organization that receives US government funds? *42. The juror said that she might hold the defendant's failure to testify against him since she would not have heard his side. Does the juror believe that the defendant has the burden or obligation to explain what happened? Would she be able to accept and follow an instruction that the defendants do not have the obligation to explain anything, that the government has the obligation to prove its case beyond a reasonable doubt?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 16 of 36 PageID #: 992

Juror #79 What part of Brooklyn does the juror live in? 4. What school does she work for? 10. Does she travel for work? *43. The juror responded that for religious reasons, she may have difficulty following the judges instructions. If the judge told her the law of the United States, which applies in this courtroom, would she be able to follow that law and impose it here?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 17 of 36 PageID #: 993

Juror #80 Where does the juror live? *4(g). What was the jurors business? When did she own this business? *15. Would the jurors work with the NYCCS/Office of Legal Affairs interfere with her ability to be fair? Would she give more weight to testimony of government officials? *35. What has the juror heard about the defendants? Has she formed an opinion about the defendants? Would she be able to set aside anything she has heard and decide the case based solely on the evidence presented in this trial and the law? *39. If the juror heard that the defendants made lots of money from the non-profit, could she be fair?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 18 of 36 PageID #: 994

Juror #81 4. What was her previous job? 6. Who does she live with? What do they do for a living?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 19 of 36 PageID #: 995

Juror #82 *4(g). What was the nonprofit theatre company that the juror worked for? What did the juror do for it? What is NSLIJ? What did the juror do for it? 4(i). Where is his spouse a waiter? *10(b) The juror said he had a corporate credit card and that he traveled. Where did he travel? Did he charge expenses to the credit card? Did he submit receipts for reimbursement? Did he have a per diem? Would he be able to put his personal experiences aside and decide this case not on the way things were done in his job but based on the evidence presented here and the law? *15. What was his job at the NSLIJ? *17. What is ASCIA and what does he do? *42. The juror responded that he is unsure if he could follow the law regarding defendants choosing to not testify. Could he set aside his personal feelings and follow the law?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 20 of 36 PageID #: 996

Juror #83 4(b). Where at Park Services did the juror work? *4(i). Would the juror give more weight to law enforcement testimony? Would her spouses job as a police officer influence her? *10(b). What did the juror use the credit card for? Did she have to account for the expenses on the credit card?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 21 of 36 PageID #: 997

Juror #84 4d. What restaurant did she manage? 4e. Who does she provide social work to?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 22 of 36 PageID #: 998

Juror #85 *2. What is the court date with the jurors son? 4e. What does she do for the credit union? 4i. What was her spouse's previous job? 4j. Where did she live previously?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 23 of 36 PageID #: 999

Juror #86 *2. The juror says that she has pain in her legs and knees. Would this interfere with her ability to sit throughout the trial? *26. The juror responded that she had been involved in a civil proceeding with a furniture store. Please explain. *34. The juror responded I guess that she could follow the Courts instructions. Would she be able to follow the courts instructions? If not, please explain.

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 24 of 36 PageID #: 1000

Juror #87 *4. What non profit did the juror work for? *4(g). For which organization was the juror a board member? *10(a). Was the juror required to put in expenses for any business travel? *17. What does she do in connection with the NYS Regional Economic Development Counsel and the NYC Mayors Commission for an Age Friendly NYC? *25. Who was her former employer? When she says she testified, what did she testify about? What court was this in? Was she immunized? *35. What does she know about the State Senate? *36. What does she do with: United Way of NYC; NYC Employment & Training Coalition; and Henry Street Settlement?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 25 of 36 PageID #: 1001

Juror #90 Where does the juror live? *2. Will the jurors high blood pressure interfere with serving on this jury? 4. Where did the juror work as a security guard? 4(h). What are his childrens occupations? 19. The jurors answer to question 19 was illegible. What is his primary source of news?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 26 of 36 PageID #: 1002

Juror #91 - The Juror Should Be Dismissed For Cause Because He States That He would Interpret Failure of Defendant To Testify As Guilt *2. Will the jurors diabetes interfere with his ability to serve on the jury? *10(c). Did the juror have to submit expense reports to his employer? *11. Will his fathers former job as a police officer influence his opinions in this case? Will he give more weight to law enforcement? *12. Will his mother-in-laws former job as a State of Wisconsin Prosecuting Attorney for tax fraud influence his opinions in this case? Would he be biased in favor of the prosecution? *42. He says he would interpret a defendant's failure to testify as guilt. If he was instructed that the defendant does not have a burden of proof and he cannot hold this against the defendant, is he 100% sure that he could put the defendant's failure to testify out of his mind?

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Juror #92 4. Who does the juror work for? *4(e). Please explain what her specific duties in the risk management department are. *4(g). How often does the jurors church board of directors meet? What is the Juror's role on the Board? 9. Which school is the juror attending? How long has she been a student there?

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Juror #93 18. What is the ASCAP?

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Juror #94 Which neighborhood of Queens does the juror live in? *3. Is the juror fluent in English? 4(b). What is a food runner? 4(j). Where has he previously lived?

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Juror #95 Which neighborhood of Brooklyn does the juror live in? 4(e). Please describe his job and job responsibilities. 4(j). Where has he previously lived? 9. When did he get his Masters Degree?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 31 of 36 PageID #: 1007

Juror #96 4a. Who was the juror's previous employer? *27. SHOULD BE RAISED PRIVATELY - Juror said she was sexually abused - did she report this to authorities? Would anything about this experience interfere with her ability to be fair here? Also, her brother was the victim of identity theft. Would anything about this experience cause her to be biased or interfere with her ability to be fair here? 34 and 35. The juror had strong opinions about politicians and ended up saying in response to question 35(f) that she was not sure that she could be fair because "I believe that most politicians think they are invincible and that can lead to abuse of their power or authority." Would the jurors feelings about politicians and Espada cause her to begin the case biased against Espada? Would her feelings interfere with her ability to decide this case solely on the evidence? Is she 100% certain that she could set these feelings aside? 35. What has the juror seen on the news about the Espadas? Is she biased against the Espadas based on what she has seen on the news? Is she 100% certain that she could set aside her feelings and decide this case solely based on the evidence and the law?

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Juror #97 4(b). What prison does the juror work in? *11. Would he give more weight to law enforcement testimony? Would he favor the prosecution? *25. The juror responded that he testified in a case about a domestic dispute. What was the domestic dispute case? *35. What has the juror heard about the defendants? Where has he heard about the defendants? How often? Would he be able to put this aside?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 33 of 36 PageID #: 1009

Juror #99 *2. Will the jurors depression and anxiety interfere with her ability to serve on this jury? To what extent has her mental illness affected her ability to hold down a job? What is the learning disability mentioned in her answer to question 2? 4(i). Where does her husband work? 21. The juror responded that she visits Facebook everyday. Will she be able to no post anything or discuss anything about the case or her jury services? *34. The juror has strong biases against politicians. Could she put aside her opinions and be fair? 41. The juror responded she did not understand the question. Please follow up.

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Juror #101 Which neighborhood of Brooklyn does the juror live in? *4. Has the juror ever had a job? Is he currently looking for a job? What does he want to do? What do his parents do for a living?

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Juror #102 4(i). Where did the juror live before his current address? 9. Where did he go to college? 15. Where is the jurors mother an accountant? Would that influence his opinions in this trial?

Case 1:10-cr-00985-FB Document 115-1 Filed 03/12/12 Page 36 of 36 PageID #: 1012

Juror #103 Where does the juror live? *2. The juror responded that he will have difficulty serving on a jury because he is the only source of income for his family. Will he be paid for jury duty by his employer? 4. Who is his employer? 4(i). What was his spouses previous job? 4(j). Where did he live previously? *40. The juror did not respond fully to question 40. Will he be able to avoid media coverage of the trial?