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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

UNITED STATES OF AMERICA      . CRIMINAL ACTION NO.
                              . 4:00-CR-054-Y
VS.                           .
                              .
THOMAS REEDY   (1)            . November 27, 2000
JANICE REEDY   (2)            . 2:05 p.m.
LANDSLIDE, INC.(3)            .
.    .    .    .    .    .    .

VOLUME I
TRIAL TRANSCRIPT OF PROCEEDINGS
BEFORE THE HONORABLE TERRY R. MEANS
UNITED STATES DISTRICT JUDGE, and a jury.

APPEARANCES:
 

For the United States:         Ms. Terri M. Moore
                               Mr. Ronald C.H. Eddins
                               Assistant United States Attorneys
                               801 Cherry Street, Suite 1700
                               Fort Worth, Texas 76102
                               (817) 252-5200

For Defendant Thomas           Mr. Wes Ball
Reedy and Landslide, Inc.:     Ball & Hase
                               4025 Woodland Park Boulevard
                               Suite 100
                               Arlington, Texas 76013
                               (817) 860-5000

For Defendant Janice Reedy:    Mr. Michael P. Heiskell
                               Johnson, Vaughn & Heiskell
                               600 Texas Street, Second Floor
                               Fort Worth, Texas 76102-4612
                               (817) 877-5321

Official Court Reporter:       Eileen M. Brewer
                               501 West Tenth Street
                               Fort Worth, Texas 76102-3637
                               (817) 334-0104

Proceedings recorded by mechanical stenography, transcript produced by computer-aided transcription.

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P R O C E E D I N G S,

        THE COURT: This is Cause No. 4:00-CR-054-Y.

Ms. Moore, who are your witnesses?

        MS. MOORE: Steed Huggins, S-T-E-E-D; Dane Ritcheson;

and Steve Nelson.

        THE COURT: All right. Gentlemen, would you please

raise your right hands to be sworn.

    (The three witnesses are sworn.)

        THE COURT: All three have said "I do." You're now

sworn and required to appear upon request of the government.

    Ms. Moore, when do you wish these gentlemen to return?

        MS. MOORE: At 8:30 a.m. in the morning.

        THE COURT: 8:30 a.m. in the morning, gentlemen.

You're free to go until then.

    All right. We'll be bringing in the jury, and I'll be

back here upon their having been seated.

    (Court in recess, 2:06 p.m. until 2:15 p.m.)

        THE COURT: Let's be seated.

        This is Cause No. 4:00-CR-054-Y, United States of America

versus Thomas Reedy, Janice Reedy, and Landslide, Incorporated.

    Are the parties ready to proceed?

        MS. MOORE: The government is ready, Your Honor.

        MR. BALL: Defendant Tom Reedy and Landslide are

ready, Your Honor.

        MR. HEISKELL: Defendant Janice Reedy is ready, Your

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Honor.

        THE COURT: Thank you.

    I'm Judge Terry R. Means, and I will be presiding over the

trial of this case. The first thing we need to do is to have

each of you stand and raise your right hands and take the oath

as a potential juror. So if you'll please stand at this time.

And please raise your right hand and take this oath.

    (The jury panel is sworn.)

        THE COURT: You may be seated. Was there anyone

among you who could not answer the question and the oath with

the words "I do"?

    (No response.)

        THE COURT: All did say "I do." Thank you.

    This is a criminal case in which the defendants are named

in 89 counts of an indictment charging them with conspiracy and

certain overt acts in violation of federal laws prohibiting

interstate transportation of visual depictions of minors

engaging in sexually explicit conduct. Twelve jurors are to be

seated plus four alternate jurors.

    Those not selected for jurors here will be reporting back

to the District Clerk's Office for further instructions for

possible service in other cases later in the month.

    We're going to conduct what is called a voir dire

examination at this time. "Voir dire" is a Texas corruption of

the French words voir dire, and I've deduced that no

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self-respecting Texan is going to go around saying the words

voir dire, so we've corrupted it into voir dire. However you

say it, though, it means the same thing: to speak the truth.

    And that's what we're going to ask you to do here today as

we ask you certain questions that will be supplemental to the

questions you've already answered on the juror questionnaire

that you've already filled out.

    We will just ask you to answer the questions that I pose

to you and the questions that the parties pose to you as simply

and as honestly as you can. There are no correct or incorrect

answers, because these relate to you and your background and

what you may have done in the past or what your attitudes are.

    One thing that is important here is that we find out if

you have a bias, a prejudice, a sufficient leaning one way or

the other that would prevent you from being fair and impartial

in this case.

    I'm not suggesting that to you so you can find a quick way

to get off of this jury. It's your duty to serve if you can

serve. However, we do know that it is a part of the human

condition that people have biases and prejudices that they

develop from experience, from upbringing, or from other

sources. And if you find that you have a bias or a prejudice

that would prevent you from serving on this jury fairly and

impartially, we will want to know that.

    Now, this may be loosely referred to at times as a child

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pornography case, and we're not going to tell you that you must

favor laws against or in favor of child pornography in order to

be a fair and impartial juror. You may very well be opposed to

what the law says is a crime, or you may be opposed to the law

and say that shouldn't be a crime. The question that will be

posed to you, though, is not either one of those. The question

that will be posed to the final jurors in this case is: Has

the government shown the defendants, or any one of the

defendants, beyond a reasonable doubt to have committed the

crime that is alleged.

    You will not have to decide whether you believe the law is

correct or not. That's for the legislature. The job you will

have is to answer the factual question of whether the

government has shown beyond a reasonable doubt that one or more

of these defendants has violated that law.

    The prosecution in this case is being pursued on the basis

of an indictment. That indictment is not evidence of guilt of

any of the defendants. It's merely a formal means of bringing

an accusation. It's nothing more. It is an accusation and

nothing more. All of us have, from time to time, been accused

of something we did not do, and you should begin this case

assuming that this accusation is nothing more than that. It

gives notice to the government what it must prove. It gives

notice to the defendants what they must defend against, and

that's all.

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    Is there anyone here who believes that because a person

has been accused of something there must be some evidence

against them and would consider that as evidence in this case?

    (No response.)

        THE COURT: And no one would. All right.

    Now, there has been some pretrial publicity about this

case. I believe there was something in one of the papers

today. I'm not sure. I haven't seen it myself. Have any of

you heard or read anything about this case?

    (A few hands raised.)

        THE COURT: All right. Let me get names, because

we'll want to talk to you in private a little later. First of

all, is it Mr. Moxon?

        VENIREPERSON MOXON: Yes.

        THE COURT: Okay. Let me just go row by row. Anyone

else on the first row?

    (No response.)

        THE COURT: Okay. Anyone else?

    Yes, sir, Mr. Tunnell.

        VENIREPERSON TUNNELL: Yes, sir.

        THE COURT: Others on the first row?

    (No response.)

        THE COURT: All right. Second row.

    (Prospective Juror No. 21 raises hand.)

        THE COURT: You're Mr. Rose?

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    Others on the second row?

    (No response.)

        THE COURT: Third row?

    (A few hands raised.)

        THE COURT: All right. You must be Mr. Ryan?

        VENIREPERSON RYAN: Yes.

        THE COURT: Others on the third row. Yes, ma'am.

Are you Ms. Walling?

    VENIREPERSON WALLING: Yes.

        THE COURT: Others on the third row I didn't see.

    (No response.)

        THE COURT: Fourth row.

    (No response.)

        THE COURT: Fifth row.

    (A few hands raised.)

        THE COURT: All right. Mr. Shaw. And is that

Mr. Goates?

    VENIREPERSON FULLER: Fuller.

        THE COURT: Fuller. I'm sorry, sir.

    Others on the last row?

    (No response.)

        THE COURT: Anyone else who's had his memory jogged

by the question? The question was: Have any of you -- Do any

of you know anything about this case or believe you know

something about this case by word of mouth, by reading, or

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hearing something in the media?

    (Prospective Juror No. 42 raises hand.)

        THE COURT: Yes, ma'am, Ms. Crow.

    Okay. Anyone else?

    (No response.)

        THE COURT: All right. Thank you.

    There will be a point after a while at which we'll bring

you forward individually to discuss what you think you may have

heard or read so that we can determine whether that may

influence you to the point you could not be a fair and

impartial juror.

    At this time I will introduce to you the defendants in

this case. Mr. Thomas Reedy, if you'll please stand, sir.

Mr. Thomas Reedy is a defendant, and also Janice Reedy. Both

defendants in this case, and there's a corporate defendant,

Landslide, Incorporated. And, Mr. Reedy, I presume you're

representing that corporation --

        MR. BALL: Yes.

        THE COURT: -- as an officer; is that correct?

        MR. BALL: Yes.

        THE COURT: All right. You may be seated.

    Do any of you know either of the Reedys or have heard of

Landslide, Incorporated? Do any of you know any one of them?

    (No response.)

        THE COURT: And no one does. All right.

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    I'll ask, then, the counsel for the government, Ms. Moore,

 to introduce herself and others at her table.

        MS. MOORE: My name is Terri Moore. I'm an Assistant

United States Attorney here in Fort Worth. And at the table

with me is Mr. Ron Eddins. Mr. Eddins is also an Assistant

United States Attorney.

    Bob Adams. Mr. Adams is an inspector with the United

States Postal Inspection Service. And Mike Mead. Mr. Mead is

also an inspector with the United States Postal Inspection

Service.

        THE COURT: I didn't catch his name. Your name, sir?

        INSPECTOR MEAD: Michael Mead, M-E-A-D.

        THE COURT: Do any of you know any of the persons who

were just introduced to you by Ms. Terri Moore on behalf of the

United States?

    (Prospective Juror No. 43 raises hand.)

        THE COURT: All right. Are you Mr. Murray or

Mr. Mitchell?

        VENIREPERSON MITCHELL: Mitchell.

        THE COURT: Mr. Mitchell, would you please stand,

sir. You said that you know one of these persons. Who is it

that you know?

        VENIREPERSON MITCHELL: Mike.

        THE COURT: Mike Mead?

        VENIREPERSON MITCHELL: Yes, sir.

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        THE COURT: How do you know him?

        VENIREPERSON MITCHELL: I work for the postal

service.

        THE COURT: Okay. Have you ever been over to his

home?

        VENIREPERSON MITCHELL: No.

        THE COURT: You don't know him personally as a friend

of yours, or is he just an acquaintance?

        VENIREPERSON MITCHELL: Just an acquaintance.

        THE COURT: Okay. How long have you known him?

        VENIREPERSON MITCHELL: I guess about six months.

        THE COURT: Okay. During that time, have you had any

difficulties or disputes with him?

        VENIREPERSON MITCHELL: No, sir.

        THE COURT: Have you ever been to lunch with him?

        VENIREPERSON MITCHELL: No, sir.

        THE COURT: All right. So you don't know him very

well.

        VENIREPERSON MITCHELL: No, sir.

        THE COURT: Would anything about your acquaintance

with him prevent you from being fair and impartial to the

defendants in this case?

        VENIREPERSON MITCHELL: (Pause.) I don't think so.

        THE COURT: Okay. You hesitated a little bit. Does

that mean that you don't, it would not affect you, or you're

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uncertain?

        VENIREPERSON MITCHELL: I'm uncertain.

        THE COURT: Okay. I'll probably ask you to come up a

little bit later and we'll discuss that further.

    Anyone else who recognizes any of the persons who were

just introduced to you by Ms. Moore?

    (No response.)

        THE COURT: All right. I'm going to then ask the

government counsel to identify for you by name and, if

necessary, other identifying characteristics or facts of who

will testify for the government in this case.

    If you hear a common name like Bob Jones, go ahead and

when I ask you if you know someone who is on the list and Bob

Jones is on the list and you know a Bob Jones, go ahead and

raise your hand and then we'll determine whether that Bob Jones

is the same one that she's talking about.

        MS. MOORE: Steve Nelson, he's a Dallas police

detective. Mike Marshall, he used to work for Microsoft; now

works for the Attorney General for the State of Texas. Joe

Ullmann, U-L-L-M-A-N-N, FBI. Steed, S-T-E-E-D, Huggins, United

States Postal Inspection Service.

    Dane Ritcheson, United States Postal Inspection Service.

Jerry Patterson, United States Postal Inspection Service. Don

Smiddy, United States Postal Inspection Service. David Cruz;

Carol Clark; Rex Rector, works for the SEC; Frank Super, FBI;

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Donna Kibbie, FBI; Dan Mikolay, United States Customs;

Ms. Mendoza that works for IBM just as a records custodian.

    I can't pronounce this. Hang on.

    (Ms. Moore confers with case agent.)

        MS. MOORE: David Hirobayashi from Sharp computers;

Sharon Girling, police detective from England. That's about

it.

        THE COURT: All right. Do any of you know any of the

persons whose names were just listed for you by the United

States Attorney?

    (No response.)

        THE COURT: And no one does. All right.

    Mr. Ball, would you please introduce those at the defense

table.

        MR. BALL: Good afternoon. My name is Wes Ball. I'm

an attorney with an office in Arlington. I practice primarily

here in Tarrant County. Seated next to me is Thomas Reedy, my

client. I also represent a corporation called Landslide,

Incorporated.

    Seated next to Mr. Reedy is Mike Heiskell, an attorney

here in Fort Worth, Texas. Mr. Heiskell will be representing

Janice Reedy, one of the defendants who's seated down at the

end of counsel table in the pink sweater.

    Also with us, sitting over here are Nona Dodson and

Jennifer Lapinski. They're assisting us in this trial.

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        THE COURT: Do any of you know any of the persons

whose names were just called out for you and introduced to you

by Mr. Wes Ball, counsel on behalf of Mr. Reedy?

    (No response.)

        THE COURT: And no one does. Thank you.

    As I mentioned to you, this is a case that involves an

allegation of interstate transmission of depictions of sexual

activity by minors, and I would then ask: Do any of you have a

bias or a prejudice in favor of or against the government in a

case like this? A bias or a prejudice in favor of or against

the government in a case like this?

    (Prospective Juror No. 19 raises hand.)

        THE COURT: Yes, sir, Mr. Delario.

        VENIREPERSON DELARIO: Yes, I do.

        THE COURT: Okay. Could you stand, please. Could

you be a little more explicit.

        VENIREPERSON DELARIO: I believe it's not right

to have minors, children, photographed for the benefit of

adults --

        THE COURT: Well, you're --

        VENIREPERSON DELARIO: -- in sexual activity.

        THE COURT: Right. And your opinion is in direct --

directly parallel and is in keeping with what the law is in

this country. We have a law that prohibits that sort of thing,

and the question that we'll have here is, not so much do you

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agree with that law or oppose that law, because it's perfectly

appropriate for you to have your opinion that that's not

appropriate and ought to be illegal, and in fact it is illegal.

The question that we'll have to pose to you is suppose that you

were placed in the jury box here. Could you look at the facts

of the case and consider just those facts that will be put on

to the jury from the witness chair and in the exhibits and

decide whether or not the government had proven its case beyond

a reasonable doubt. Could you do that, and could you do that

without bias or prejudice in favor of the government?

        VENIREPERSON DELARIO: I'm not sure based on the

question asked. Now or later or what I hear? I don't know how

to answer that right now.

        THE COURT: Okay. Let me see if I understand. You

are concerned that because of the intensity of your feelings

that you might favor the government and not be able to give the

defendants a fair trial?

        VENIREPERSON DELARIO: That's correct.

        THE COURT: Okay. Well, we may explore that more

later. Thank you, sir.

    Is there anyone else? All right.

    (Prospective Juror No. 45 raises hand.)

        THE COURT: Are you Ms. Hindman?

        VENIREPERSON HINDMAN: Yes, sir.

        THE COURT: Please stand. Tell me what you wanted to

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say.

        VENIREPERSON HINDMAN: Pretty much what you had asked

him. I don't know if I could -- I would be in agreement, of

course, with the government. But I don't know if I could

fairly state whether a person is guilty or not because of

strong feelings.

        THE COURT: All right. Thank you.

    I think I might be able to draw an analogy to a drug case

a little bit better. We have this question come up in drug

prosecutions all the time. People have very strong feelings

about drugs and drug trafficking. Of course, that's totally

different from this case, but it may help show the point.

    The question in a drug case is not whether you agree with

the drug laws. Some people agree and some people disagree.

Some people think that drugs should be legalized. The question

in those cases is: At the conclusion of all the evidence, has

the government shown the defendant in a drug case to have

delivered marihuana or delivered cocaine or possessed it with

intent to deliver, whatever the indictment is.

    So the focus of the jury is on the facts, not on the law.

The law is my job. The facts belong to the jury, and so we

will be asking each of you not to focus on the law but to focus

on the facts.

    Now, if your attitude is such that you are so opposed to

depictions of minors in this way, or you believe strongly that

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that's a First Amendment question and you don't think there

should be any laws against it at all, we will ask you can you

put those aside to the point that you can look at the facts and

determine whether the government has proven its case beyond a

reasonable doubt that that law was violated.

    So I would say again to the two of you who have expressed

forthrightly and honestly your concern about bias, think about

those matters. We'll take it up with you a little bit later.

We appreciate your honesty and forthrightness on it.

    Anyone else?

    (Prospective Juror No. 31 raises hand.)

        THE COURT: Yes, ma'am. Ms. Blum?

        VENIREPERSON BLUM: I feel like I just couldn't be

unbiased, because I have such strong feelings against

pornography of any kind, much less children.

        THE COURT: All right. Thank you.

    Anyone else?

    (No response.)

        THE COURT: All right. Thank you very much.

    Do any of you have any religious, moral, or ethical

convictions that would prevent you from sitting in judgment of

another person? I'm not talking about this case, but there are

some people who believe that either because of their religion

or other influences that it is inappropriate to sit in judgment

of another person and that serving on a jury would be sitting

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in judgment of another person. Anyone who believes that?

    (No response.)

        THE COURT: And no one does. All right. Thank you.

    I've mentioned a couple of times here already that the

burden will be on the government to prove its case beyond a

reasonable doubt. That raises this possibility. It may be

possible at the end of this case you will believe that one or

more of the defendants is probably guilty. The question,

though, will be has the government proven that person or

persons guilty beyond a reasonable doubt.

    So you could believe that someone is probably guilty but

still have a reasonable doubt about whether they are in fact

guilty. Can you see how that could happen? Anyone who cannot?

Anyone please tell me if you do not understand what I'm talking

about.

    (No response.)

        THE COURT: All right. Ms. Quirk, you've been paying

close attention. What would be the appropriate verdict if you

believed that a person was probably guilty but you're not

convinced beyond a reasonable doubt?

        VENIREPERSON QUIRK: I could not render a verdict.

        THE COURT: Or would the verdict appropriately be not

guilty?

        VENIREPERSON QUIRK: Yes, yes.

        THE COURT: All right. Anyone who disagrees with

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that?

    (No response.)

        THE COURT: The appropriate verdict in a jury case

where the jury believes that a defendant probably committed the

crime but is not convinced beyond a reasonable doubt is not

guilty. Anyone who fails to understand that, or understands it

and disagrees?

    (No response.)

        THE COURT: Anyone?

    (No response.)

        THE COURT: All right. So to go over it one more

time. This is very important. If at the conclusion of this

case you believe that one or more of the defendants is probably

guilty but you're not convinced beyond a reasonable doubt, I

think you're telling me that you would vote not guilty. Anyone

who could not vote not guilty?

    (No response.)

        THE COURT: And everyone could. All right. Thank
you.

    This next question will bleed over into a question I asked

previously that Mr. Delario and Ms. Hindman reacted to. Also,

Ms. Blum. But if you were on trial here today, would you want

someone like yourself sitting on your jury, or are you just the

kind of person that's likely to convict, especially where

there's an allegation made like in this case? Anyone?

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    (No response.)

        THE COURT: Concerned about having someone like

yourself on your jury?

    (No response.)

        THE COURT: All right. Thank you.

    This case is likely to take this entire week to try. I've

awarded a certain number of hours to each side, and I believe

that we can complete this case this week. The attorneys are

not real happy about it, but I've got to try to finish this

case this week because I've got another trial or two next week.

So I'm going to tell you we'll probably complete this case this

week.

    Is there anyone here who has such pressing personal or

business matters that you believe you just should not or cannot

serve on this jury?

    (Prospective Juror No. 15 raises hand.)

        THE COURT: Yes, sir. Are you Mr. Morgan?

        VENIREPERSON MORGAN: Yes, sir.

        THE COURT: Please stand.

        VENIREPERSON MORGAN: Right now I'm interviewing for

a job right now. We have one car, and so if I'm gone with the

car then my wife can't get to work nor pick our children up

from school. We also have a four-year old at home so when

she's gone to work, then I take care of him. So it is very

difficult.

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        THE COURT: Okay. Hold on. You may be seated.

    (Court confers with court coordinator.)

        THE COURT: Are you the primary caregiver for your

children?

        VENIREPERSON MORGAN: No, I wouldn't be the primary

caregiver, I guess.

        THE COURT: Well, your wife is currently employed?

        VENIREPERSON MORGAN: Part-time.

        THE COURT: She's part-time?

        VENIREPERSON MORGAN: Right.

        THE COURT: And you're looking for jobs just now.

        VENIREPERSON MORGAN: That's correct.

        THE COURT: And how many children do you have?

        VENIREPERSON MORGAN: Three.

        THE COURT: What are their ages?

        VENIREPERSON MORGAN: Four, ten, and fourteen.

        THE COURT: Four, ten, and fourteen. What happens to

the four-year old while your wife is at work?

        VENIREPERSON MORGAN: I take care of him.

        THE COURT: Okay. If you both were working, what

would you do?

        VENIREPERSON MORGAN: I'm not sure. I guess we would

have to get someone to take care of him at that point. We

haven't done that.

        THE COURT: Okay. And in the immediate past both of

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you have not been working?

        VENIREPERSON MORGAN: Not -- There's always been

someone home to take care of him.

        THE COURT: Okay. We'll take that into

consideration. Thank you, sir.

    Anyone else?

    (No response.)

        THE COURT: All right. Now, I've asked you several

questions. I don't always cover the waterfront. Is there any

question that I failed to ask or any fact that I failed to

elicit that you think we ought to know that would relate to

your ability to serve on this jury, either from a time

standpoint, an interest standpoint, or from the standpoint of

fairness? Anything we ought to know.

    (Prospective Juror No. 7 raises hand.)

        THE COURT: Yes, sir, Mr. Moxon

        VENIREPERSON MOXON: Medical.

        THE COURT: Are you the person I saw --

        VENIREPERSON MOXON: I suffer from migraine

headaches, maybe more than one a week.

        THE COURT: Are you the fellow I saw in the elevator

this morning?

        VENTREPERSON MOXON: I don't know.

        THE COURT: Okay. Didn't make an impression on you

if I did.

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Okay. Migraines. Do you have one now?

        VENIREPERSON MOXON: I took some medication for one

this morning.

        THE COURT: When you're taking medication, are you

sleepy or do you have trouble paying attention?

        VENIREPERSON MOXON: Sometimes.

        THE COURT: Let me delve into that just a little bit

more. Well, we're going to talk to you privately anyway about

pretrial publicity, so we'll cover that then. Help me

remember. Be sure and raise the question about your migraines.

    Anyone else?

    (No response.)

        THE COURT: All right. Thank you.

    I'm going to read to you something that relates again to

burden of proof and reasonable doubt, just a couple of

paragraphs, but I want you to listen carefully and then at the

conclusion of that reading I'll ask you a question or two.

    In a criminal case the burden is on the government to

prove that the defendant is guilty beyond a reasonable doubt.

This is a different and higher standard than the preponderance

of the evidence standard that is applied in civil cases. The

law presumes a defendant to be innocent of a crime. Thus, a

defendant, although accused, begins the trial with a clean

slate, that is, with no evidence against him. And the law

permits nothing but legal evidence presented before the jury to

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be considered in support of any charges against the accused.

    So the presumption of innocence alone is sufficient to

acquit a defendant unless the jurors are satisfied beyond a

reasonable doubt of the defendant's guilt after careful and

impartial consideration of all the evidence in the case.

    It's not necessary that the government prove its case

beyond all possible doubt. The test is one of reasonable

doubt. A reasonable doubt is a doubt based upon reason and

common sense, the kind of doubt that would make a reasonable

person hesitate to act. Proof beyond a reasonable doubt must,

therefore, be proof of such a convincing character that a

reasonable person would not hesitate to rely and act upon it in

the most important of his own affairs.

    A defendant is never to be convicted on mere suspicion or

conjecture. The burden is always upon the government to prove

guilt beyond a reasonable doubt. This burden never shifts to

the defendant for the law never imposes upon a defendant in a

criminal case the burden or duty of calling any witnesses or

producing any evidence.

    Is there anyone on the panel who could not follow the law

concerning burden of proof or reasonable doubt as I just read

it to you?

    (No response.)

        THE COURT: And all can. Thank you.

I've mentioned to you previously -- I want to reiterate it

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-- that the defendants are brought here on an indictment. The

indictment is not evidence. It is simply a method by which the

government brings a person to trial.

    Once again, is there anyone on the panel who believes that

simply because a defendant has been indicted this is, in and of

itself, some evidence of guilt?

    (No response.)

        THE COURT: And no one does. What you're saying by

agreeing with me on that is that these defendants have a clean

slate, and at this moment they are innocent of the charges and

will only be found guilty if you find from the evidence that

they've been shown to be guilty beyond a reasonable doubt. And

it has to be unanimous.

    In a criminal case a defendant does not have to testify.

It's a fundamental, constitutional law that in this country a

person may not be required to testify and may not be required

to present any evidence. That's another way of saying we don't

require a defendant to prove the case -- to disprove the case

against him. And to require a defendant to testify or to put

on evidence would be to place the burden on its head and say

the defendant has to testify. A defendant, instead, has the

right to insist the government prove its case without any help

at all from him or her. So that will be what will be done

here.

    Is there anyone here who has a quarrel with that notion,

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VOL I, 25

with that idea?

    (No response.)

    THE COURT: Is there anyone here who would hold it

against any of these defendants if they elected not to testify?

    (No response.)

        THE COURT: Is there anyone here who would hold it

against any of these defendants if they elected not to put on

any testimony?

    (No response.)

    THE COURT: I take it by your silence you would not

hold that against them, and you will look to the government to

prove its case all by itself beyond a reasonable doubt. Anyone

disagree?

    (No response.)

    THE COURT: All right. Thank you.

    Do any of you have a special disability or problem that

would make it difficult or impossible for you to serve as a

member of this jury?

    I've heard from Mr. Moxon about migraines. Anyone have a

particular difficulty with seeing? Hearing?

    (Prospective Juror No. 29 raises hand.)

        THE COURT: All right. Let me see, Mr. Stone. Could

you stand, please, sir. Oh, you're Mr. Lynn.

        VENIREPERSON LYNN: I have trouble hearing.

        THE COURT: Okay. How have you heard so far from

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VOL I, 26

there?

        VENIREPERSON LYNN: I couldn't hear you plainly, but

maybe if I sit closer I might.

        THE COURT: Right. But you've heard most of what's

gone on, do you think?

        VENIREPERSON LYNN: Most everything, yes, sir.

        THE COURT: Okay. You would be sitting much closer.

Can you hear me now?

        VENIREPERSON LYNN: Yes.

        THE COURT: Okay. I'm going to guess you can serve

and that what we would do is if you had difficulty hearing at

any particular point, we would just ask you to raise your hand

and we would repeat what was just said.

        VENIREPERSON LYNN: Thank you.

        THE COURT: Thank you.

    Anyone else, trouble with sight or hearing?

    (Several hands raised.)

        THE COURT: Yes, Ms. Walling?

        VENIREPERSON SPINDOR: Spindor.

        THE COURT: I'm sorry, Spindor.

        VENIREPERSON SPINDOR: I have a problem hearing,

also, but I do hear fairly well with one ear.

        THE COURT: Me, too.

    All right. So far you think you've been able to follow

things?

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VOL I, 27

        VENIREPERSON SPINDOR: Yes, sir.

        THE COURT: Okay. Good. Anyone else? I think --

Yes, sir, Mr. Robertson.

        VENIREPERSON ROBERTSON: Yes. I think you pretty

well answered my question. I'm having to strain, but I think

I'm hearing what you're saying. If I can hear better over

there, I guess I could handle it.

        THE COURT: Okay. Thank you.

    And, yes, sir, that is Mr. Fuller -- or Mr. Goates?

        VENIREPERSON GOATES: Goates. I've heard maybe half

of what's been said to this point.

        THE COURT: All right.

        VENIREPERSON GOATES: I can't understand most of

what's been said.

        THE COURT: Why don't you go ahead and move up here

to the first row. Mr. Goates is No. 58, and he's moving up to

sit next to No. 12, Ms. Clements.

    Does that help?

        VENIREPERSON GOATES: Yes, sir.

        THE COURT: Okay. Others who have difficulty seeing,

hearing, or some other disability that might prevent you from

serving or serving very well? Anyone?

    (No response.)

        THE COURT: All right. Thank you.

Have any of you ever been -- I usually have to do this by

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VOL I, 28

row, because we usually have a number of positive responses.

Do any of you now work for a law enforcement agency, or any

member of your family or a close friend employed by law

enforcement? Before you answer, let me define family. By

"family" I just mean your children, your brothers and sisters,

or your parents. We don't want to get into aunts, uncles, and

cousins and nephews and nieces. Just your children, your

brothers and sisters, and your parents. Any of them ever been

employed, or have you ever been employed by a law enforcement

agency? First row.

    (Prospective Juror No. 1 raises hand.)

        THE COURT: Yes, sir, can you help me with your name.

        VENIREPERSON LABRUYERE: LA-BRIAR.

        THE COURT: That's not so hard, is it?

    Mr. Labruyere, would you please stand. Tell me who that

is that's been involved with law enforcement.

        VENIREPERSON LABRUYERE: My father was a sheriff

in Ector County.

        THE COURT: In which county?

        VENIREPERSON LABRUYERE: Ector.

        THE COURT: Okay. And how long ago was that?

        VENIREPERSON LABRUYERE: Twenty years ago.

        THE COURT: Were you at home when he was there?

        VENIREPERSON LABRUYERE: (Nods head.)

        THE COURT: So you heard tales around the dinner

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VOL I, 29

table about his work, I guess.

        VENIREPERSON LABRUYERE: Right.

        THE COURT: Anything about that time and the tales

that he would tell or the information he would bring home that

would prevent you from being fair and impartial in this case?

        VENIREPERSON LABRUYERE: No, sir.

        THE COURT: All right. Thank you.

    Others on the first row?

    (No response.)

        THE COURT: Second row?

    (Several hands raised.)

        THE COURT: Mr. Goates.

        VENIREPERSON GOATES: Does that include military

police?

        THE COURT: Yes, sir.

        VENIREPERSON GOATES: I was in the military police in

the service over 30 years ago.

        THE COURT: All right. How long did you so serve?

        VENIREPERSON GOATES: I'm sorry?

        THE COURT: How long did you serve?

        VENIREPERSON GOATES: I was in the military police 13

months, 13 days.

        THE COURT: I guess that says you didn't enjoy it all

that much.

        VENIREPERSON GOATES: I transferred from the Air

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VOL I, 30

Force to the Army.

        THE COURT: All right, sir. Anything about that that

would prevent you from being fair and impartial in this case?

        VENIREPERSON GOATES: No, sir.

        THE COURT: All right. Thank you.

    And then I think on the next row we had a couple of ladies

who were answering yes. Ms. Reynolds.

        VENIREPERSON REYNOLDS: Yes, sir. My first husband

was a policeman for the City of Fort Worth.

        THE COURT: Okay. And anything about your time with

him and the things that you knew because of being married to

him that would prevent you from being fair and impartial in

this case?

        VENIREPERSON REYNOLDS: No, sir.

        THE COURT: All right. Thank you.

    And, Ms. Havens.

        VENIREPERSON HAVENS: Yes, sir. I worked for the

City of Arlington and I worked there for 15 years. I've been

retired from there for about five years now.

        THE COURT: Okay. And so you're not working in any

law enforcement now.

        VENIREPERSON HAVENS: Not right now, no, sir.

        THE COURT: Anything about your 15 years with the

Arlington PD that would prevent you from looking at this case

fairly and impartially in making up your mind about whether the

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government has proven its case beyond a reasonable doubt, based

solely on the evidence that would be presented in the case from

the witness chair?

        VENIREPERSON HAVENS: I'd do the best I could to make

a fair judgment.

        THE COURT: Once more, please.

        VENIREPERSON HAVENS: I said I'd do the best I could

to make a fair judgment.

        THE COURT: Okay. Now, having heard that, do you

believe that you would be able to follow the instructions of

the Court to be fair and impartial and to make up your mind

based solely on what you see and hear from the witness chair

and see in exhibits?

        VENIREPERSON HAVENS: I'll do the best I can.

        THE COURT: You don't want to let me pin you down, do

you?

        VENIREPERSON HAVENS: No, sir.

        THE COURT: What is your concern, if any, about your

ability to be fair and impartial?

        VENIREPERSON HAVENS: During my time working, I've

heard and seen so many things that just -- it's not close to

what I worked with but it might interfere with it.

        THE COURT: All right. I'm inferring from what

you're saying that you're concerned about your ability to be

fair and impartial.

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        VENIREPERSON HAVENS: I want to be fair and I'll do

the best I can to be fair. I'm not going to say I'm not going

to be.

      THE COURT: All right. I may need to discuss things

with you further later, but maybe not. Thank you very much. I

appreciate your forthrightness.

  (Court confers with court coordinator.)

        THE COURT: Anyone else on the second row involved in

law enforcement or related or a friend of someone who is?

    (No response.)

        THE COURT: All right. Proceeding to the third row.

Anyone?

    (No response.)

        THE COURT: And the fourth row?

    (No response.)

        THE COURT: And the last row?

    (Prospective Juror No. 56 raises hand.)

        THE COURT: Yes, ma'am, Ms. Gerhardt.

        VENIREPERSON GERHARDT: My mother worked for Esmor in

Fort Worth.

        THE COURT: Worked where?

        VENIREPERSON GERHARDT: Esmor.

        THE COURT: I still didn't understand that.

        VENIREPERSON GERHARDT: At Esmor.

        THE COURT: That's a town?

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        VENIREPERSON GERHARDT:  No, security here in Fort

Worth.

        THE COURT: Oh, it's a security company?

        VENIREPERSON GERHARDT: Uh-huh. No, I don't know

what they call it, but that's where they parole the sexual

offenders here in Fort Worth.

        THE COURT: Okay. Anything about your conversations

with him (sic), if any, that would affect your ability here to

be fair and impartial, both to the government and to the

defendants?

        VENIREPERSON GERHARDT: My mother never talked about

her work at home. I just knew that's where she worked.

        THE COURT: Okay. So the fact that she worked for

law enforcement, just that simple fact, would not affect your

ability to be fair and impartial?

        VENIREPERSON GERHARDT: She never brought any of it

home with her, so I don't know of anyone that was paroled there

or what they did or what she did.

        THE COURT: All right. Thank you.

    Anyone else on the last row?

    (No response.)

        THE COURT: Anyone who's had his memory jogged now by

hearing the others?

    (Prospective Juror No. 23 raises hand.)

        THE COURT: Yes, ma'am. You're Ms. Reynolds?

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        VENIREPERSON REYNOLDS: I made a mistake.

        THE COURT: Okay.

        VENIREPERSON REYNOLDS: My first husband was a

policeman in Kingsville, Texas.

        THE COURT: All right. Any difference now in where

he served? Does working in Kingsville make you a little less

willing to serve or able?

        VENIREPERSON REYNOLDS: No.

        THE COURT: Okay. Thank you.

    All right. Anyone else?

    (No response.)

        THE COURT: All right. Have any of you at any time

been involved in a criminal matter that concerned yourself, a

member of your family as I've defined it, or a close friend, as

a witness or a victim? Once again, have any of you been

involved in a criminal matter that concerned yourself, a member

of your immediate family as I've defined it, or a close friend,

as a witness or a victim? First row.

    (Prospective Juror No. 3 raises hand.)

        THE COURT: Yes, sir. Mr. Wood.

        VENIREPERSON WOOD: Yes, sir. My 15-year old

daughter was kidnapped. It's been about 16 years ago.

        THE COURT: All right. I hope she was returned to
you.

        VENIREPERSON WOOD: Four hours later.

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        THE COURT: Okay. Anything about that traumatic

event that would prevent you from being fair and impartial in

this case?

        VENIREPERSON WOOD: No.

        THE COURT: All right, sir. Thank you.

    Others on the first row?

    (Prospective Juror No. 5 raises hand.)

        THE COURT: Yes, sir, Mr. Otwell.

        VENIREPERSON OTWELL: Me and my family, including my

dad and mother, are in a lawsuit right now over some

misappropriation of money, and we were told and told our money,

this and that, and it's a scam more or less.

        THE COURT: So is that a civil case?

        VENIREPERSON OTWELL: No, it's not. It's at the

county level at this point.

        THE COURT: Now, are you the plaintiff? Are you

suing to get your money back?

        VENIREPERSON OTWELL: Yes, but my dad and my uncle

are the two people, I guess, whose names appear most often.

But I'm involved in it and I've lost money on it, also.

        THE COURT: Okay. Is there a criminal case that's

coming out of that as well?

        VENIREPERSON OTWELL: I feel like there is. There

are two different states. This person that is implicated in

this case, there are two other states, Alabama and Wisconsin,

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VOL I, 36

which is involved in this.

        THE COURT: Okay. Anything about your experience in

that case that would prevent you in any way from being fair and

impartial to both sides in this case?

        VENIREPERSON OTWELL: No, sir.

        THE COURT: All right, sir. Thank you.

    Continuing on the first row.

    (No response.)

    THE COURT: Second row? Again, the question: Have

any of you been involved in a criminal matter that concerns

yourself or a member of your family or a close friend as a

witness or a victim?

    (No response.)

        THE COURT: Third row?

    (No response.)

        THE COURT: Fourth row?

    (Prospective Juror No. 44 raises hand.)

        THE COURT: Yes, ma'am, Ms. Murray.

        VENIREPERSON MURRAY: Yes. I was a witness on a

murder trial.

        THE COURT: Hold on just a second. We need to get

Mr. Forehand some water.

    (Brief pause in proceedings.)

        THE COURT: Okay. Ms. Murray, tell me about your

brush with a criminal matter.

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VOL I, 37

        VENIREPERSON MURRAY: In high school my senior year

my ex-best friend committed a murder. I wasn't with him at the

time, but I was with him the other day so I had to be -- I was

a witness against him.

        THE COURT: Okay. Anything about that very difficult

situation that would prevent you from being fair and impartial

here?

        VENIREPERSON MURRAY: No, that was some years ago.

        THE COURT: Did you believe that he was fairly

treated by the authorities?

        VENIREPERSON MURRAY: Uh-huh.

        THE COURT: So you don't have any complaint about

that?

        VENIREPERSON MURRAY: No.

        THE COURT: Okay. Thank you very much.

    Others on the fourth row?

    (No response.)

        THE COURT: And on the last row?

    (Prospective Juror No. 50 raises hand.)

        THE COURT: Yes, ma'am, are you Ms. Lykins?

        VENIREPERSON LYKINS: Uh-huh.

        THE COURT: Okay.

        VENIREPERSON LYKINS: I was a victim of a crime. My

16-year old brother-in-law was murdered here in Fort Worth in a

a drive-by shooting.

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        THE COURT: All right. Were you with him or near him

at that time?

        VENIREPERSON LYKINS: No. He was just like my son,

though.

        THE COURT: But, I mean, you were not present.

        VENIREPERSON LYKINS: No, sir.

        THE COURT: Okay. Anything about that very tragic

situation that would prevent you from being fair and impartial

in this case to the government and to the defendants?

        VENIREPERSON LYKINS: No, sir.

        THE COURT: All right. Thank you.

    Anyone else who's had his memory jogged by these questions

and answers?

    (No response.)

        THE COURT: All right. When the evidence begins to

be put on by the government, undoubtedly some of the witnesses

will be representatives of the government, that is, they'll be

in law enforcement. And when they take the stand we will ask

you to give no greater credence or believability to any of

those witnesses than you would to any other witness. In other

words, we will ask you not to give additional credibility,

believability, to a law enforcement witness than you would to

any other witness, whether presented by the government or by

the defendants.

    We will ask you to make credibility assessments once you

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VOL I, 39

hear their testimony. We will ask you to observe them and to

determine whether you believe they are telling the truth or

they have a good memory, whether they seem to be comfortable

with what they're saying, that sort of thing. We will want you

to make credibility assessments and not just assume every

person is as credible as the next.

    But we will ask you not to make that credibility

assessment based on what they're wearing or what they do for a

living. Anyone here who would find that difficult to do?

You're just so impressed with or so loyal to law enforcement

officials that you would feel a need to lean in their direction

and give their testimony greater credence or believability?

Or, on the other hand, you've had a bad brush with the law or

law enforcement and you are more inclined to disbelieve what they

say. Anyone?

    (No response.)

        THE COURT: All right. No one does. All right.

Thank you.

    I have granted the parties some additional time to ask you

some questions on their own. I've given the government 15

minutes and the defendants ten minutes each.

    Ms. Moore, you may proceed.

        MS. MOORE: Thank you, Your Honor.

    Hopefully, I won't take all 15 minutes, but there are, I

guess, essentially two areas that I want to talk a little bit

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VOL I, 40

with you about and ask you how you feel about some things. And

I hope that you will do just like you've done with the Judge,

just speak up if I say something where you know I'm talking to

you, okay?

    The Judge told you that this case is about essentially

child pornography. That's what we've accused the defendants of

doing is aiding in the conspiracy and aiding and abetting in

the transportation, promotion of child pornography.

    Now, the other thing that the Judge told you is that it's

the government's job, it's our duty, to prove this case to the

jury beyond a reasonable doubt. And so what does that mean

exactly? That means that I have a job to do in this courtroom

and that is I've got to convince whatever 12 people are put

over here, I've got to convince each and every one of those

folks, you folks, that these people did what the indictment

accuses them of doing.

    And one of the things that has to be done in proving that

is you're going to, unfortunately, have to view some terrible

pictures. I think -- You know, I can't go into the facts of

the case and everything here at jury selection. That's really

for the people once the jury is picked to hear the facts, but I

can tell you that. And here's something that worries me about

that. If you don't speak up and say something about it now

and you're sitting over in the jury box and you fall out, okay?

Some people just might not be able to handle it, because it's

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VOL I, 41

bad.

    What would we do then? We've got to have 12 jurors to

continue on. Well, now, the Judge will pick -- you know, there

will be some alternates here, but that's not really fair to

say, oh, it's a little hotter in here than I anticipated. Let

him do my job for me, or let her step in for me. I really

don't like this. It's not the time to speak up over there once

you're picked. The time to speak up is now, okay, before we

get started. And so you be thinking about that, because I'm

going to ask you if you're going to be up to the task.

    The other thing that I have to worry about is if you're

shown these terrible pictures that I'm telling you is coming

your way, are you going to get mad at the government? Okay.

Some people might do that, and I'm not here to criticize you

if you're one of those people. I'm not here to argue with you or

try to change your mind about it, because, you know, you're

entitled to your opinions. I just want to know what they are,

okay, before you're picked and put over here in the box and

then it's kind of too late.

    And so I would be worried about somebody saying, well, I

cannot believe, Ms. Moore, that you brought that in here and

made me look at that. I'm mad at you and, therefore, I'm going

to vote not guilty. See, that would be something I would worry

about, right? Can y'all see that? Maybe I'm just being

paranoid, but that's something I would worry about, quite

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frankly.

    And you heard the Judge say it's my duty, it's my burden

of proof, so I've got to do that. It's not that I want to make

your life miserable or make you sick at your stomach or make

you have a nightmare. I've got to prove that.

    And so take it from the defendant's point of view, too. I

just told you my point of view. I would setting here worried

you would think, oh, my goodness. I'm mad at you. I can't

believe you brought that in here. I'm just going to vote not

guilty to teach you a lesson. First of all, let me ask you

that before I take it from the defendants' point of view. Is

there anybody here that feels like that that's what they would

do? And, again, I'm not going to try to change your mind. I

just want to know.

    (Prospective Juror No. 49 raises hand.)

        VENIREPERSON KOPOLOWICZ: I don't believe -- I just

can't look at the pictures.

        MS. MOORE: Okay. So it's not that you would take it

out on anybody. You just think you would be one of those that

just fell out. If you saw it, you couldn't handle it.

        VENIREPERSON KOPOLOWICZ: Right.

        MS. MOORE: Okay. And let me say this. Just like

it's my job I've got to show you this stuff. It's your job,

you got to look at it, okay? The jury has to make a decision

on whether it is or is not child pornography and whether it is,

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VOL I, 43

you know, these people are guilty of promoting it. And so if

it's your job, you got to look at it. I think what I hear you

saying, and, sir, I should have asked you for your name so the

court reporter can write that down. I'm sorry. And way back

there, would you stand up, please.

        VENIREPERSON KOPOLOWICZ: Gary Kopolowicz.

        MS. MOORE: Okay. And you're saying that as a juror

you wouldn't be able to do your job and look at it?

        VENIREPERSON KOPOLOWICZ: Not if pictures are

involved.

        MS. MOORE: There's pictures.

        VENIREPERSON KOPOLOWICZ: I can't.

        MS. MOORE: Like I say, I can't go into the facts of

the case, but I can tell you that.

        VENIREPERSON KOPOLOWICZ: I can't.

        MS. MOORE: You couldn't handle it. Okay.

    And, sir?

        VENIREPERSON OTWELL: My name is Dennis Otwell.

        MS. MOORE: Yes, sir.

        VENIREPERSON OTWELL: Well, I can't say how I would

react. I would hate that it would come to the point where I

would have to look at it, but I don't think that I would just

fall on my face or anything. But that's pretty embarrassing to

me. I'm just not used to that.

        MS. MOORE: And, you know, who is? Really, who is?

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VOL I, 44

Nobody is going to sit there in that jury box and look at that

and not feel some kind of an emotion.

        THE COURT: Let me say this, Ms. Moore. It's not as

though we're going to ask you to concentrate on them or spend a

lot of time looking. You will have to see them, apparently.

I'm not going to prejudge that, but apparently you'll be

presented with some photographs. But it's not as though you're

going to be asked to study each one.

    Okay. Go ahead.

        MS. MOORE: That's true. You don't have to sit there

and take a microscope to it. You can look it at it and --

Anyway. And, again, you're going to feel something. Of course

you will. You wouldn't be a human being.

    My question right now is: Would you be so angry at the

government that even if we proved a case beyond a reasonable

doubt you would refuse to go forward?

        VENIREPERSON OTWELL: No.

        MS. MOORE: Would anybody feel that way? And, again,

I wouldn't be fussing with you about it or trying to change

your opinion. I just want to know.

    Yes, ma'am.

        VENIREPERSON QUIRK: I've never seen child

pornography, and I'm afraid if I did see it I would not blame

the government. I would, more or less, blame the defendant.

        MS. MOORE: Okay. Well, let's talk about that,

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VOL I, 45

because I just got though saying let's take it from the

defendants' point of view and then I backed up and said, well,

let's finish this first.

    Well, let's take it from the defendants' point of view.

What if, and I'm certainly not saying it's the case in this

situation, but what if they weren't guilty? Okay. What if you

had somebody accused of something and they just didn't do it,

but yet the government is up here showing bad picture after bad

picture. Would you just say, I don't care if they didn't prove

you're guilty or not, just because they showed me bad pictures

I'm going to find you guilty. That doesn't hardly sound fair,

does it?

    I mean, you have to take a look at it and say, yes, it is

or is not child pornography, but you have to look at the other

evidence and say are these people responsible? Did these

people do what the government said they did?

    We have to prove what we call elements of the offense.

The statute lays it out, you know, that this person did

knowingly, okay, transport child pornography. So you got to look

at it to see if it's child pornography. You got to look at it to

see if it was transported. You got to look at it to

see if they knowingly did it. Okay? You have to break it down

and look at the elements of the offense.

    And just as I would be worried that somebody might say

that is so terrible I'm just going to punish you for showing it

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to me, you can see how these people would be worried that you

just see a bad picture and want to punish somebody. That

wouldn't be fair either, would it? And, again, you see stuff

and it's bad, but you still have to hold it together. You know

what I mean? And make a fair decision about what is the truth,

you know, in this courtroom. And it may be just because

there's a bad picture doesn't mean these people are

automatically guilty. So you can't let your emotion carry you

through that you just want to punish somebody because the

government showed you a bad picture. Do you see both sides of

what I'm trying to say here?

    Now, is there anybody here that feels like if I see a bad

 picture, somebody is going to be punished, regardless of

whether you've got a case or not?

    (No response.)

        MS. MOORE: Nobody feels that way. Okay. You're

just being honest about seeing stuff like that would tend to,

you know, be upsetting.

        VENIREPERSON QUIRK: (Nods head.)

        MS. MOORE: That's natural. What if it was a

homicide case, and you had to see pictures of the deceased?

You know, that's offensive. That's terrible. It's something

you would rather not have to do, but if you're called upon to

be the juror to do it, can you do your job and do it? And make

that fair decision --

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        VENIREPERSON QUIRK: (Nods head.)

        MS. MOORE: -- without just being carried by the

emotion of a picture,

    Okay. Y'all are not saying anything, but I see some

people shaking your heads, so if anybody disagrees with that,

will you speak up. Otherwise, I'll assume we're on the same

page.

    (No response.)

        MS. MOORE: All right. That's the first thing I want

to talk to you about, and I know my time is running out.

        THE COURT: You have five minutes.

        MS. MOORE: Thank you, Judge.

    Here's the second thing I want to talk to you about, and

that's -- I noticed on your questionnaires that some of you

have had jury duty before, and you've actually served on a

criminal case. But a lot of people have not, and so there are

different ideas in the law that are out there that some of you

that have had jury duty may know about and some folks might

not. Have you ever heard of aiding and abetting? Have you

ever heard of that? It's the same thing as if you've been down

to the state courthouse they call it the law of parties, okay?

But it's aiding and abetting.

    What does aiding and abetting mean to you, sir? I don't

have my list of everybody's name, but you're right here on the

front row.

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        VENIREPERSON FOREHAND: James Forehand.

        MS. MOORE: Are you related to Bill Forehand in any

means, by the way?

        VENIREPERSON FOREHAND: No.

        MS. MOORE: Okay. Mr. Forehand, what does aiding and

abetting mean to you?

        VENIREPERSON FOREHAND: Helping out, basically.

        MS. MOORE: Helping somebody out. Okay. And I want

to make sure that you understand that concept. Aiding and

abetting, a person can be guilty of a crime -- Well, let me

just tell you what I expect at the end of the trial, after the

jury has heard all the evidence, the Judge reads what's known

as the Court's Charge. In the Court's Charge it tells you what

the law is, and that's the law that you have an oath to follow.

And I'll just tell you what I expect the Judge will tell you

that aiding and abetting is, okay?

    The law recognizes, ordinarily, anything a person can do

for himself may be accomplished by that person through the

direction of another person as his or her agent, or by acting

in concert with, or under the direction of, another person or

persons in a joint effort or enterprise.

    If a person is acting under the direction of the

defendant, or if the defendant joins another person and

performs acts with the intent to commit a crime, then the law

holds the defendant responsible for the acts and conduct of

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VOL I, 49

such other persons, just as though the defendant had committed

the acts or engaged in the conduct.

    So, in other words, take Bob Adams here. He's a postal

inspector. Say Bob wants to burglarize some mailboxes, all

right? He's going to do the dirty work. He's going to be the

one to actually bust into the mailbox and steal the mail. So

he's obviously guilty. Well, but he needs somebody to be the

lookout for him, right? He needs somebody to go peek and look

around the corner and make sure nobody is coming and holler at

him and let him know, you know, if it looks suspicious. So

that's me. So I'm standing there looking, "Hurry up, Bob.

Hurry up, Bob. Somebody is coming down the hall, Bob."

    Now, am I guilty? Of course. I didn't lay my hands on

the mailbox. I never put my hands on the stolen mail, but you

can see that I'm into it up to my eyeballs. I am acting under

his direction. I am aiding and abetting.

    Is there anybody here that disagrees with that law? Do

you think that's a good law? You think we ought to have

that law?

    Okay. I see y'all shaking your heads. Anybody who thinks

we should not have that law? Bank robber goes into rob the

bank. He's got a get-away driver. The get-away driver never

goes in the bank, never has a gun in his hand, never scares

anybody and says, give me the money, but he's got that engine

revved up, okay. He's aiding and abetting. Is that a good

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thing, or should we just convict the bank robber and let the

get-away driver go home? Okay. So you understand that idea.

    Does anybody have any questions of me? It may be your

only chance?

    (No response.)

        MS. MOORE: No questions for the government.

    (Prospective Juror No. 23 raises hand.)

        MS. MOORE: Yes, ma'am.

        VENIREPERSON REYNOLDS: Is the jury allowed to take

notes?

        MS. MOORE: That would be a question for the Judge.

It's his courtroom. He'll run that.

        THE COURT: Yes, you will be allowed to take notes.

        MS. MOORE: Okay. Thank you so much.

        THE COURT: Mr. Ball, do you have additional voir

dire?

        MR. BALL: Yes, Your Honor. May it please the Court,

members of the government, ladies and gentlemen. I'm allotted

ten minutes, so I'll talk a little fast here, and I appreciate

your honest and candid responses to the questions as I go over

them.

    The one thing that I noticed on the questionnaire, before

I talk a little bit about the subject matter, was -- the Judge

talked to you a little bit about the burden of proof is on the

government and they have to prove what they've accused the

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VOL I, 51

defendants of beyond a reasonable doubt. And I do -- I won't

specify which questionnaire it was, but there was someone or

several people said one of the considerations in the case would

be whether the defendants might have shown their innocence.

And I just want to make a clarification. Does everyone

understand, or is there anyone who does not understand, that we

don't have to prove anything.

        THE COURT: Mr. Ball, could you speak into the

microphone just a little better?

        MR. BALL: Yes, sir.

        THE COURT: Thank you.

        MR. BALL: Is there anyone who believes that the

defendants have to prove that they're innocent before they're

entitled to a verdict of not guilty? Let me phrase it that

way.

    (No response.)

        MR. BALL: Because that's not our obligation under

the law. Some people feel that way, and that's fine. Is there

anyone who feels that way?

    (No response.)

        MR. BALL: I take it without a show of hands, no one

feels that way.

    I want to talk to you just a second about the concept of

censorship, and I'm not specifically directing this question at

the beginning to anything involving children or child

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pornography. I'm just talking about censorship in general.

And my question is: On a scale of one to five with one being

strongly against and five being strongly in favor, what best

describes your feelings about censorship in general?

    And let me just pick on someone if I can. Mr. Forehand,

I'm just talking about censorship in general, not any

particular content or material. Are you strongly against,

strongly in favor?

        VENIREPERSON FOREHAND: It's kind of hard. I mean, I

could be favorable in one area and not in another.

        THE COURT: I'm going to have to ask everyone, when

you respond, to stand. It's just so hard to hear all the way up here.

        MR. BALL: If you would stand, please sir.

        VENIREPERSON FOREHAND: I have a hard time just

saying that generally. There are a lot of different kinds of

censorships. If you want to pin me down, I would put myself

right in the middle.

        MR. BALL: All right. Let me direct it to what

adults see on the internet. Let me narrow it down a little

bit.

        VENIREPERSON FOREHAND: Well, it depends as to

whether it's public or private, at your house. If it's the

internet and the like, I think there should probably be

censorship there. Anybody who has access to the internet, it's

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VOL I, 53

there.

        MR. BALL: All right. And what about adults,

consenting adults, looking at sexually explicit material? I'm

not talking about involving children, just material that may be

protected by the First Amendment.

        VENIREPERSON FOREHAND: I guess I don't believe in

censorship there.

        MR. BALL: All right. Would you be strongly against

it in that sort of --

        VENIREPERSON FOREHAND: I'd be morally and personally

against it, but as far as censorship, I would say no.

        MR. BALL: Thank you, sir. If I understood your

answer, as far as consenting adults looking at sexually

explicit material on the internet, you were strongly against

censorship, I take it, as long as it didn't involve children.

Was that a fair characterization?

        VENIREPERSON FOREHAND: Yes.

        MR. BALL: All right. Let me look on the first row.

Who, I guess, disagrees with his response to that? And some of

you do. I mean, some people are offended by any type of

sexually explicit material at all, and that's fine.

    (Prospective Juror No. 10 raises hand.)

        MR. BALL: Yes, ma'am, you're Ms. Maloney.

        VENIREPERSON MALONEY: I would be against. I mean, I

would be for censorship, and just because I've got strong moral

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beliefs, I would rather there not be pornography on the

internet.

        MR. BALL: Okay. And you would be in favor -- Do you

have any idea who might be responsible -- if you had the choice

to censor it, would you think it would be the role of the

government or others or do you know?

        VENIREPERSON MALONEY: I don't know. I guess whoever

governs over what goes on the internet. I'm not that

knowledgeable of the internet to know who would be in charge of

that. But I have a 16-year old and I would not want him to be

able to get on the internet and see some of the things that are

there.

        MR. BALL: All right. And, actually, the law

prohibits children from being able to access that material, or

it's against the law to show them that material.

        VENIREPERSON MALONEY: I just don't think it's right.

        MR. BALL: Okay. Let me ask you a question that

really directs itself to your -- I think your -- I'm looking at

the wrong number here. Bear with me just a second.

    I think there's a question on the questionnaire with

regard to the type of material someone might be asked to see if

they sit as a juror on this case, and I believe you indicated

that with regard to abuse of children and stuff, you have a

tendency, if you hear about it or read about it, to cry.

        VENIREPERSON MALONEY: I'm very sensitive to it. I'm

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a schoolteacher and have been around some children that have

had to be removed from their home. I just become very

emotional. It would be very difficult for me to see what I

might be asked to see. I guess I'm being selfish and maybe I

might be haunted by it, by things after it.

        MR. BALL: Okay. I mean, as Ms. Moore explained to

you, you might be called upon, if you sit as a juror in this

case, to look at some pretty unpleasant and graphic photographs

or images. And she's correct. A concern we might have is that

a juror might be carried away simply by what they're seeing and

be so overcome emotionally that they want to get somebody, and

whether the rest of the proof is sufficient or not these are

the folks here, we'll just vote them guilty because the

pictures are so horrible. Do you follow what I'm saying?

        VENIREPERSON MALONEY: Yes. And since there's been

questions asked, I do think I would be fair in my judgment, but

I think selfishly that it's going to affect me.

        MR. BALL: Do you feel like, in spite of the effect,

you can be fair to Mr. and Ms. Reedy?

        VENIREPERSON MALONEY: Yes.

        MR. BALL: Thank you. I appreciate your candid

answer.

    In regard to what she had to say, some folks feel like

that this material, that sexually explicit material on the

internet or elsewhere, should be censored. And I'm not talking

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VOL I, 56

about child pornography and I'm not talking about children

looking at them. I'm talking about consenting adults. With

regard to the answer Ms. Maloney gave, does anyone on the first

row agree with her answer?

    (No response.)

        MR. BALL: And thinks the material ought to be

censored?

    What about the second row, is there anyone who is strongly

in favor of censoring sexually explicit material on the

internet that's seen by consenting adults that doesn't involve

children?

    (Prospective Juror No. 23 raises hand.)

        MR. BALL: Yes, ma'am. Is it Reynolds?

        VENIREPERSON REYNOLDS: Yes, sir.

        MR. BALL: I'd appreciate you standing if you would,

please. What are your feelings about that? Are you strongly

in favor of censoring that type of material?

        VENIREPERSON REYNOLDS: Yes, sir. I'm not sure who

should do it, but I just think it's horrible.

        MR. BALL: All right.

        VENIREPERSON REYNOLDS: Very demeaning.

        MR. BALL: Do you feel like if you heard someone was

involved in the adult entertainment business showing sexually

explicit material to consenting adults that did not involve

children, would your opinions about that cause you to rush to

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VOL I, 57

judgment about whether they were guilty of distributing child

pornography?

        VENIREPERSON REYNOLDS: I think I would have to look

at all the facts.

        MR. BALL: All right. Thank you, ma'am.

    Anyone else on that row?

    (No response.)

        MR. BALL: How about the third row --

    (Prospective Juror No. 31 raises hand.)

        MR. BALL: -- in favor of censorship? Yes, ma'am.

Is it Blum?

        VENIREPERSON BLUM: Yes. I feel that it should be

censored, and I don't see the purpose in it and why do we need

it?

        MR. BALL: All right. Do you have any notions or

given any thought who might be responsible to do that, to

censor it?

        VENIREPERSON BLUM: No.

        MR. BALL: What about other types of material that

don't have sexual orientation, controversial reading material,

anything like that, do you have an opinion about --

        VENIREPERSON BLUM: Yes. I think the books that our

children are required to read should be taken out of the

schools.

        MR. BALL: All right. Thank you. Ms. Blum, thank

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VOL I, 58

you very much.

    Anyone else on that row?

    (Prospective Juror No. 35 raises hand.)

        MR. BALL: Yes, ma'am, you're Ms. Walling?

        VENIREPERSON WALLING: I agree with the lady.

        MR. BALL: Maloney, I believe it was.

        VENIREPERSON WALLING: I don't think it should be

there for anyone.

        MR. BALL: For anyone, okay. What about other types

of material? Let's take it away from sexually explicit

material. Controversial reading material.

        VENIREPERSON WALLING: Personally, I still just -- I

just don't think it should be there.

        MR. BALL: All right.

        VENIREPERSON WALLING: That's just my own opinion.

        MR. BALL: Anyone else on that row?

    Thank you for your candid answer.

    (No response.)

        MR. BALL: How about the fourth row?

    (Prospective Juror No. 40 raises hand.)

        MR. BALL: Yes, sir, Mr. Stone -- or Mannella, I

believe. Yes, sir, could you please stand.

        VENIREPERSON MANNELLA: Who polices the airwaves,

television and radio? The reason I'm asking that is it seems

like consenting adults are only allowed to say certain things

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on the airwaves. They tell you, you can't say that on the

radio. You can't say that on TV. Somebody is policing that.

        MR. BALL: What's your opinion about that, that that's

policed?

        VENIREPERSON MANNELLA: Well, what I'm saying is

we're sitting here saying should material be censored between

consenting adults. Consenting adults watch television and

listen to the radio, so I don't see why it shouldn't be. I

don't see that that material is really necessary for society.

        MR. BALL: All right. Okay. You asked a question

who does that.

        VENIREPERSON MANNELLA: Yes, the radio and TV.

        MR. BALL: Do you have an opinion on who ought to?

        VENIREPERSON MANNELLA: Well, I guess it's the board

that's in charge over the airwaves that's supposed to be public

domain. And so they're not allowed to say these things by some

law or they would be doing it.

        MR. BALL: Okay. All right. I appreciate that, sir.

Thank you.

    Anyone else on the fourth row?

    (Prospective Juror No. 45 raises hand.)

        MR. BALL: Yes, ma'am, Ms. Hindman.

        VENIREPERSON HINDMAN: I just think it should be

censored. I don't think there should be any, whether it's

reading or pictures or graphics.

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        MR. BALL: All right. Let me ask you this: If you

served as a juror and someone was in the type of business of

showing sexually explicit material that didn't involve

children, would you become so angry at their business that you

would find them guilty of something the government --

        VENIREPERSON HINDMAN: I don't like adult pornography

nor children pornography.

        MR. BALL: All right. And I guess my question is:

If someone was in the adult entertainment or the business of

distributing adult material, was involved in that activity that

did not involve children as a subject, in other words, they

were showing sexually explicit material to consenting adults

who apparently wanted to see it, would your opinion about their

business and the type of activity they're engaged in, you'd be

so angry at what they did that you would have a tendency to

find them guilty of, let's say, a child pornography case even

if the government didn't prove that they were involved in

child pornography?

        VENIREPERSON HINDMAN: Honestly, I don't know. I

don't know how to answer that.

        MR. BALL: All right. Can you see how I'm concerned

about that?

        VENIREPERSON HINDMAN: Sure I do, and, you know, my

emotions toward it, just, you know, reading the questionnaire,

not knowing that's what this was going to be over, was so

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upsetting to me, you know. So I don't know what my reaction

would be emotionally once it's put towards me. And it being

something so important, I don't know what else to tell you.

        MR. BALL: All right. Thank you, ma'am.

    Anyone else on that row?

    (Prospective Juror No. 38 raises hand.)

        MR. BALL: Yes, sir, Mr. Weatherly?

        VENIREPERSON WEATHERLY: I just don't believe it

ought to be there.

        MR. BALL: All right. And, again, we're talking

about sexual oriented material that portrays adults, consenting

adults. You would be in favor of censoring that material.

        VENIREPERSON WEATHERLY: Yes, sir.

        MR. BALL: All right. Do you have any notion about

who ought to be responsible to do that?

        VENIREPERSON WEATHERLY: No, sir.

        MR. BALL: Okay. Thank you, sir, for your honest

opinion.

    Anyone else on that row?

    (No response.)

        MR. BALL: I guess the last row.

    (Prospective Juror No. 50 raises hand.)

        MR. BALL: Okay. There's someone in the back there,

Ms. Lykins?

        VENIREPERSON LYKINS: I think there should be

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censorship. It's just too easy to do a search and end up in

one of these sites. I mean, I've innocently gone into one of

these and have been very offended. It's just too easy to get

into them.

        MR. BALL: Okay. Well, let me ask you that. I take

it you've made use -- and it's on the questionnaire -- you've

made use of the internet from time to time and you've gone on

there and typed something in wanting to go see something and

you inadvertently ended up somewhere else?

        VENIREPERSON LYKINS: Right.

        MR. BALL: Something that was out of your control,

went to a place you didn't want to be?

        VENIREPERSON LYKINS: Yes.

        MR. BALL: Do you have any particular, other than

just surfing the net, do you have any particular knowledge

about how the internet works? Computers?

        VENIREPERSON LYKINS: I know a little bit.

        MR. BALL: How the information travels and so forth?

        ENIREPERSON LYKINS: Uh-huh.

        MR. BALL: Have you ever been involved in creating a

web site?

        VENIREPERSON LYKINS: I just learned how to, yes. I

don't know how to go about it getting it out there. I've just

created one on my PC.

        MR. BALL: All right. Was it difficult to do?

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        VENIREPERSON LYKINS: Not too hard at all.

        MR. BALL: Can you change it rather quickly, what's

on there?

        VENIREPERSON LYKINS: I believe so.

        MR. BALL: Okay. Thank you.

    All right. Anyone else on the last row with regard to the

censorship question?

    (No response.)

        MR. BALL: Thank you. Real quickly --

        THE COURT: Mr. Ball, your time is up.

        MR. BALL: All right. Thank you for your attention.

Mr. Heiskell will have some questions for you, I'm sure. Thank

you.

        MR. HEISKELL: May it please the Court, counsel for

the prosecution, and may it please you, too, ladies

and gentlemen. My name is Mike Heiskell. I'm going to talk a

little fast as well. I only have ten minutes to talk to you,

and I want to start out by asking and following up with what

Mr. Ball asked you.

    Let me see by a show of hands, how many of you do believe

in censorship by the government?

    (Several hands raised.)

        MR. HEISKELL: Can I see a show of hands? Can you

raise them a little higher, please. And of those of you who

raised their hands, how many of you strongly believe in

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censorship, for those of you who did raise your hands?

    (Several hands raised.)

        MR. HEISKELL: Okay. How many believe that the

government should not be engaged in censorship, whether it's

over the internet or any other media?

    (Several hands raised.)

        MR. HEISKELL: I see one hand in the back. Could you

raise your hands a little higher, please.

        UNIDENTIFIED VENIREPERSON: Would you repeat the

question, please.

        MR. HEISKELL: How many of you don't believe in

censorship by the government in the media, whether it's the

internet or any other media outlet?

    (Several hands raised.)

        MR. HEISKELL: Okay. And for those of you who raised

your hands in that regard, would that include sexually explicit

material, adult material? I'm not talking about child

pornography or anything of that nature.

    (Hands raised.)

        MR. HEISKELL: Okay. I see one hand in the back.

That includes sexually explicit, okay.

    Could you raise your hands again? I'm sorry. It's real

quick and I'm trying, I know, to rush through this, but we need

to find out how you feel about this.

    (Hands raised.)

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        MR. HEISKELL: Okay. Thank you. One of the things

Ms. Moore, the government prosecutor, talked about was the

burden of proof and you should know that the elements that

she's talked about, the knowingly, the promotion, the aiding

and abetting, things of that nature, those elements have to be

proved by the government 100 percent. They've got to show

beyond a reasonable doubt those elements as to each one of

these defendants.

    I represent Janice Reedy, and I've got another concern.

She's a female, and part of the questionnaire had to do with

how you felt about females, in particular, who are charged with

a crime such as this. And a lot of you have strong religious

and moral beliefs concerning this topic in general. And then

in particular I want to ask you -- and some of you did comment

on the fact that if a female is charged in this that somehow

that's -- I think one person, Ms. Smith even, in the second

row, said it's a disgrace, or some words to that effect.

    How many of you think that just because Ms. Reedy is a

female that that somehow, in and of itself, would cause you to

lean more against her whether -- regardless of the government's

proof. Just because she's charged with this, she's a female.

How many of you feel that way?

    (No response.)

        MR. HEISKELL: Anyone? (No response.)

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        MR. HEISKELL: Okay. One of things you're going to

have to look at, folks, is not only evidence, but lack of

evidence. The government does have this high burden of proof,

and you're going to have to look at these people, not

collectively but also individually. What role did the people

play in this so-called conspiracy that you've heard about in

this so-called distribution of child pornography?

    Now, over this past Thanksgiving holiday, I took my

16-year old son to a couple of movies. He likes to go to

movies and I like to go to movies. And you've heard all the

hue and cry lately about censorship in the movies, to keep

children under the age of 17 or 16 from going to R rated

movies, for instance, and other explicit movies.

    And let me ask you in this regard: If you go to a movie

and let's say that that movie contains some objectionable

material, whether it's X rated, NC-17 -- I think that's the new

rating -- or R rating, and if you want to hold someone

responsible for that, do you think that you would look at the

ticket seller as being responsible for what is on the content

of the movie inside? Anyone?

    (No response.)

        VENIREPERSON QUIRK: Would you repeat that, please.

        MR. HEISKELL: Yes, ma'am. You have a ticket seller,

you go up to buy -- you stand in line to buy a ticket to the

movie, and you go inside the movie and all of a sudden you see

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something that you certainly didn't intend to go in and view

and it's very objectionable to you. And it could be sexually

explicit or violent or whatever the case may be. Who would you

hold responsible for that? The ticket seller? Would that be

one of the responsible persons?

        VENIREPERSON QUIRK: Is this movie already rated?

        MR. HEISKELL: Yes, ma'am, it's already rated.

        VENIREPERSON QUIRK: If it's already rated, I would

hold myself responsible.

        MR. HEISKELL: Okay.

        VENIREPERSON QUIRK: Because if it's rated an R or

NC-17, then I should not be there.

        MR. HEISKELL: Do you think the ticket seller should

be responsible at all, whether you go in and you purchase a

ticket from the ticket seller?

        VENIREPERSON QUIRK: (Shakes head.)

        MR. HEISKELL: Well, let me take it a little bit

further. What about the bookkeeper who may be in a back office

somewhere crunching numbers and looking at the invoices and

finances and making sure that all the ticket sales were

accounted for. Would you think that person would be

responsible for what is on the content of inside the movie

theater? Anyone feel that way?

        VENIREPERSON BUCHANAN: When you go see a movie or

when you buy for your children, there are guidelines for

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VOL I, 68

parents to follow. That's what the ratings are for, and at

this point in time there is no such safeguard on the internet.

It's like she said, you can be there, a child six years old can

be there browsing and ends up with some of this garbage.

    So, no, the ticket seller should not be held responsible,

but there should be some kind of guidelines for parents so they

can make a choice. So the ticket seller should not be held

responsible.

        MR. HEISKELL: Sure. And I think one of the concerns

that people across the country are looking at is holding the

people who actually produce and direct and distribute these

type of materials to be responsible. Wouldn't you agree with

that?

        VENIREPERSON BUCHANAN: You have a choice as to

whether or not you want to see that, because they are rated.

        MR. HEISKELL: Correct.

        VENIREPERSON BUCHANAN: You can read reviews, you can

find out about it, and the internet does not have that yet. So

I find that question ridiculous, quite frankly.

        MR. HEISKELL: Well, do you think that because there

is no "censorship" on the internet that anyone who surfs the

internet and comes across the material would be responsible

themselves? Is that what I'm hearing?

        VENIREPERSON BUCHANAN: Unless you're a child, yes.

It's our responsibility as a society to protect our children,

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VOL I, 69

and we have to have the tools to do that. And at this point

the people who put this information out on the internet haven't

been held responsible because that's the only option we have as

parents, to protect our children.

        MR. HEISKELL: Do you agree with what is called in

the business an adult verification service to ensure that

adults get on the internet before they get into the sexually

explicit content?

        VENIREPERSON BUCHANAN: Absolutely.

        MR. HEISKELL: Are you aware of such services being

provided?

        VENIREPERSON BUCHANAN: It's my understanding they're

in their infancy, basically.

    &n