CONFIDENTIAL JUROR QUESTIONNAIRE

Juror No. _ _ _ _ _ _ __ This questionnaire asks a number of questions of a personal or sensitive nature. The inquiry is necessary to assure that you are able to fulfill your duty to be a fair and impartial juror. The case on which you may be selected to serve as a juror may involve allegations regarding explicit sexual content. In order to assure the State and the defense a fair trial, the court must determine if you have any experience or opinions that might affect your objectivity and impartiality in such cases. Disclosure of your responses will be made only as is necessary to select a fair and impartial jury. The questionnaire is otherwise confidential. The State has brought 59 charges against the defendant, Mark W. Strong: 12 counts of Promotion of Prostitution, I count of Conspiracy to Commit the Crime of Prostitution, I count of Conspiracy to Commit the Crime of Violation of Privacy, and 45 counts of Violation of Privacy. I. Have you heard or read anything or been part of any discussion with family, friends, or co-workers about the case of State v. Mark W. Strong, the case of State v. Alexis Wright, or the cases against the following:

State v.: David Kline John Verreault MonieHobbs Harry McCann Kevin Paggliccia Phillip Parker Colin Powers Jason Rickett Norman Crepeau Joseph Cuetara Donald Hill James Soule Gary Bahlkow James White Peter W orrnell 1-licheal Dente Peter Chavonelle Matthew Diehard Patrick Heelan Lawrence Ritchie Albert Tremblay KrisKamys Bob Chabot Steven Houghton Joe Lewis

Donald Fortin Frank Parker Nathaniel Thompson Jason Nadeau Tom Powers Jason Douin Craig Patterson Stanley Cornwall Robert Hazelton Jeff Rogers Wayne Fessenden Brian Bedard Denise Sillon Ricky Dewitt Jeffrey Comeau Jeffrey Beaupre David Burley Daniel Meyer Nlichael Mcinnis William Kerr Derek Chapman Jeffrey Rogers Jay Sanborn YES _ _ _ _ _ _ _ NO _ _ _ _ __ Newspaper Television Internet Radio Discussion

2. The following people may be called to testify at this trial. Please circle any names of potential witnesses you know, are acquainted with, or are related to.

1.
2. 3. 4. 5. 6. 7.

Nicholas Higgins, Kennebunk, ME Melissa Higgins, Ripley, ME Donna L. Andrews, LCSW, Portland, ME Joseph Thornton, Private Investigator James Strong, Thomaston, ME Anthony DeWolfe, Owls Head, ME Rev. Wayne Sawyer, St. George, ME

8. 9. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28.

wlichael MacDonald, Thomaston, ME William Smith, Warren, ME William Stuart, St. George, ME Zachary Harmon, Kennebunk, ME Sgt. Mark Holmquist, Maine State Police, Major Crimes Unit (South) Det. Corey Pike, Maine State Police, Major Crimes Unit (South) Det. Ethel Ross, Maine State Police, Major Crimes Unit (South) Det. Jason Andrews, Maine State Police, Major Crimes Unit (North) Det. Terry James, Maine State Police, Evidence Response Team Det. Lauren Edstrom, Maine State Police, Evidence Response Team Det. Herb Leighton, Maine State Police, Evidence Response Team Det. George Loder, Maine State Police, MIAC Unit Det. Bernie Pender, Maine State Police, MIAC Unit Trooper Niles Krech, Maine State Police, Troop D Det. Frederick Williams, Saco Police Department, Forensic Crime Special Agent Matt Fasulo, United States Secret Service, Portland Office Joe Murphy, Cambridge Police Department Det. Lenny Bolton, Maine State Police, MIAC unit Lt. Glen Lang, Maine State Police, Maine Computer Crimes Unit Michael Desrosiers, United States Postal Service, Postal Inspector, Portland Office

29. 30. 31. 32. 33. 34. 35. 36. 37.

Chief Robert MacKenzie, Kennebunk Police Department Lt. Anthony Bean Burpee, Kennebunk Police Department Lt. Dan Jones, Kennebunk Police Department Det. David Jamieson, Kennebunk Police Department MDEA Agent Kyle Moody (Saco PD) MDEA Agent Paul Shaw (Sanford PD) Audra Presby, Kennebunk Police Department Jessica Staples, CFT, Computer Crimes Task Force Mark Soucie, EnCE, Computer Crimes Task Force

38. 39. 40. 41. 42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53. 54. 55. 56. 57. 58. 59. 60. 61. 62. 63. 64. 65. 66. 67. 68.

Dawn M. Ego, EnCE, Computer Crimes Task Force Anthony Clukey, Kennebunk Police Department Dan Racinello, Kennebunk, iYIE Bee Nyugen, 5 Woodbury Court, Portland, iYIE Christopher West, 40 High Tide Road, Kennebunk, iYIE Representative of Camden National Bank Representative ofTD Bank Representative of First N.A. Bank Representative of Bangor Savings Bank Representative of Mid Coast Federal Credit Union Representative ofVerizon Wireless Representative of US Cellular Representative of Peoples Choice Credit Union Representative of OTT Communications Paul Demers, Building Inspector, Town of Kennebunk Robert Labonte of Saco Dale Madore of North Yarmouth Dennis Sill on of Shapleigh Jens Peter Bergen of Kennebunk :Michael Sherwood of Old Orchard Beach Bradford Siegel of Cumberland Ben Bouma of Arizona Ryan Saucier of South Portland Kenneth Fairbanks of Lisbon Falls Claude Palmer of Oxford Neil McDonald of Scarborough Roger Larson of Harrison l'Yfichael Wears of Sanford Matthew Scott of Wayne Louis Solomon of Saco James Ferreira of South Portland

69. 70. 71. 72.

Clinton Joseph Ray of Portland Paul Main of Biddeford Carl Taylor of Thomaston Jason Andrews, MSP

3.

Do you have a personal or religious opposition to prostitution that would inhibit your ability to act as a fair and impartial juror? YES _ __ NO _ __

4.

Do you think prostitution is a victimless crime? YES _ __ NO _ _ __

5.

Are you of the opinion that prostitution should be legal in the State of Maine? YES _ __ NO _ _ __ UNCERTAIN_ __

6.

Have you, a member of your immediate family, or a close relative ever been charged with a crime of a sexual nature? YES _ __ NO _ __

7.

Do you have a personal or religious aversion to pornography that would make it difficult to listen to the law and evidence and render a fair and impartial verdict? YES _ __ NO _ _ __

8.

You may be shown explicit videos and photographs depicting individuals engaged in graphic sexual acts. Would viewing this evidence make it difficult for you to listen to the law and evidence and render a fair and impartial verdict? YES _ __ NO _ _ __

9.

Have you had any experiences in your life that would make it difficult or impossible for you to consider evidence in a case involving acts of a sexual nature and render a fair and impartial verdict? YES _ __ NO _ _ __

10.

Do you have a medical or physical condition that would make it impossible for you to listen to the testimony, observe the witnesses, or otherwise sit as a juror in this case? YES _ _ __ NO_ _ __

11.

Would you be able to find a defendant guilty of a crime against an individual who may also be a criminal, if the State proves each element of this crime beyond a reasonable doubt? YES _ __ NO _ __

12.

Do you hold any personal or religious beliefs or opinions that would prevent you from rendering a judgment of another person or from weighing the testimony of one person against another? YES _ _ __ NO_ _ __

13.

Do you have any personal or religious beliefs or opinions about our system of criminal justice which would make it difficult or impossible for you to listen to the law and evidence and render a fair and impartial verdict? YES _ __ NO _ __

14.

Do you believe the State spends too much in resources prosecuting crimes? YES _ __ NO _ __

15.

If the State proved beyond a reasonable doubt each element of an offense, would you be able render a verdict against the defendant, even if he was not physically present during the commission of the crime?

YES _ _ __

NO _ _ __

16.

This case may involve three weeks of testimony, from Wednesday, January 23, 2013, through Friday, February 8, 2013. Would sitting as a juror for this length of time pose a significant hardship to you? YES _ __ NO _ _ __

IF YES, WHY_ _ _ _ _ _ _ __

17.

Does the fact that the State has multiple police officers and attorneys working on a case conflict with your ideas of fairness to the point that you would not be able to listen to the law and the evidence and render a fair and impartial verdict?
YES~~~ NO~~~

18.

Do you understand that if you serve as a juror, you will be required to favor neither the prosecution nor the defense, but, rather, you will be expected to judge the evidence against the criminal defendant in a fair and impartial manner?
YES~~~

NO_ _ __

19.

Do you feel that the criminal justice system is fundamentally unfair due to the fact that the State may have more resources at its disposal than does the defendant?
YES~~~ NO~~~

20.

Adultery is defined as having sex with another person who is not your spouse; it is not a crime. Prostitution is defined as having or offering to have sex with another person for money. If the evidence shows that Defendant Mark Strong committed adultery with Alexis Wright, would that fact alone make it difficult for you to find him not guilty of the crime of Promotion of Prostitution? YES _ _ __
NO_ _ __

21.

If the evidence shows that Alexis Wright was a prostitute, would the fact that Defendant Mark Strong had a sexual relationship with her, not for money, make it difficult for you to find Defendant Mark Strong not guilty of the crime of Promotion of Prostitution?
YES~~~

NO_ _ __

22.

Have you ever told or intimated to anyone that you think Defendant Mark Strong is guilty of the charges against him? YES _ _ __
NO_ _ __

23.

Do you believe that because Defendant Mark Strong was arrested for these crimes by law enforcement officers, that he is probably guilty of these crimes?
YES~~~ NO~~~

24.

Do you think that too many guilty people get away with committing crimes?
YES~~~ NO~~~

25.

Do you believe too many innocent people are convicted of crimes they have not committed? YES _ __ NO_ _ __

26.

Do you think that if a person is charged with a crime, as Defendant Mark Strong is in this case, that that fact is evidence of his guilt? YES _ _ __ NO_ __

27.

The court will instruct you that the defendant Mark Strong does not have to present any evidence whatsoever at this trial; he does not have to prove that he is not guilty of the crimes he is charged with under the law. The State must prove that he is guilty of each crime beyond a reasonable doubt. Will you strictly follow that instruction? YES _ __ NO _ __

28.

The court will instruct you that the State must prove each element of each offense beyond a reasonable doubt. Will you strictly follow that instruction? YES NO _ __

29.

The court will instruct you that the defendant Mark Strong does not h;we to testifY in this case. He has entered a plea of "not guilty" to all the charges. Would it make any difference to you in determining defendant Mark Strong's guilt if he did not testifY in this case? YES _ __ NO _ _ __

30.

Have you ever previously served as a juror in either Federal or State court? YES _ __ NO_ _ __

31.

Have you ever previously participated in a legal proceeding as a party or witness in either a civil or criminal case? YES _ _ __ NO _ __ TYPE OF PROCEEDING _ _ _ _ __

32.

Do you know Alexis Wright or any member of her family? YES _ __ NO _ __

33.

Are you or any member of your immediate family (mother, father, brother, sister, child, or spouse) currently employed or were employed in the past in law enforcement, or do you have any close friends who are employed or in the past were employed in law enforcement?
YES _ __

NO_ _ __

34.

Have you ever worked for the York County District Attorney's Office in any capacity?
YES _ _ __

NO _ __

35.

Are you a close friend or family member of any other member of the jury pool?
YES _ __

NO _ __

36.

Do you work with any member of the jury pool?

YES _ __

NO _ _ __

37.

Will you be working an evening shift during the next three weeks?
YES _ _ __

NO _ __

38.

The court will instruct you that the defendant is presumed innocent. Will you strictly follow that instruction?
YES _ __

NO _ __

39.

Have you ever been excused from serving on a jury for any reason?
YES _ __

NO_ _ __

40.

The court will instruct you that you are not to be concerned about the consequences of any verdict you may reach. Will you strictly follow that instruction?
YES _ _ __

NO _ _ __

Under oath and subject to the penalties of perjury, I swear that the answers to the above questions are true to the best of my knowledge and belief.

Date: _ _ _ _ _ _ _ _ __

Juror Number: _ _ _ _ _ _ _ _ __

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