USA v. REED et al - RONNIE REED
Criminal

District of Columbia, dcd-1:2003-cr-00560-106469

PRELIMINARY STATEMENT as to VINCENT E. REED, RONALD REED

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA:: v.: Cr. No.03-560 (RBW): VINCENT REED, and:: RONALD REED, AKA,: PETER J. NICOLETTI, AKA,: RONNIE REED,:: Defendants.: GOVERNMENT'S PROPOSED PRELIMINARY STATEMENT AND VOIR DIRE QUESTIONS The United States of America, by and through its attorney, the United States Attorney for the District of Columbia, respectfully proposes the following preliminary statement and voir dire questions, in addition to those usually asked by this court: PRELIMINARY STATEMENT This is a criminal case in which the defendants, Vincent Reed and Ronald Reed, are charged by a grand jury with armed bank robbery and using and carrying a firearm during a crime of violence. Vincent Reed is also charged with armed carjacking, destruction of property, assault with a dangerous weapon, and unlawful possession of a firearm. It is alleged that Vincent Reed and Ronald Reed, on December 1, 2003, by intimidation, took from the person or presence of another person, a sum of money (specifically around $25,000). It is alleged that that money belonged to (and was in the care, custody, control, management and possession of) the Engraving and -2- Printing Federal Credit Union, located at 620 Michigan Avenue, N.E., Washington, D.C., on the campus of Catholic University of America. It is also alleged that the financial institution involved was insured by the National Credit Union Administration Board. It is further alleged that following the bank robbery, Vincent Reed while armed with a firearm used force and violence to take from the possession of a person his motor vehicle. PROPOSED VOIR DIRE QUESTIONS 1. Based on this information, does any member of the jury panel believe that he or she knows anything about this case? 2. Is there anything about the nature of the charges in this case that might affect your ability to render a fair and impartial verdict if you are chosen as a juror? 3. [Introduction of the defendants] 4. The United States is represented by Assistant United States Attorney Jeanne M. Hauch. The defendants are represented by Assistant Federal Public Defender David Bos and attorney Richard Gilbert. Does any member of the panel know any of the parties or legal representatives of the parties in the case? 5. During the presentation of evidence by the United States, you may hear testimony from or about the following persons: [List to be provided at trial]. 6. [Introduction of potential defense witnesses, if any.] -3- Does any member of the panel know any of the prospective witnesses in the case? 7. Some of the government witnesses are law enforcement officers. Have any of you, any members of your family, or any close friends, had an experience with any law enforcement, or police officer, or with any person associated with or employed by the United States Attorney's Office or the Court, which would make it difficult for you to be a fair or impartial juror in this case? (Answers to be taken at the bench) 8. Have you or any of your relatives or any close friends ever worked, in any capacity, for any type of law enforcement agency, including: the Federal Bureau of Investigation, the United States Secret Service, the Internal Revenue Service, the Metropolitan Police Department, the United States Marshal Service, the United States Park Police, the Immigration and Naturalization Service and any other law enforcement agency? a. If the answer is yes, what was the nature of the employment? b. Would this employment affect your ability to be a fair and impartial juror in this case? 9. Has any member of the jury panel, or any of your immediate family members or close friends, studied law or had any legal training? a. If the answer is yes, what was the nature of the -4- studies or training? b. Would this study or training affect your ability to follow the Court's instructions as to the law that should be applied in this case? 10. Have you or any of your relatives or any close friends ever worked, in any capacity, with or for a defense attorney or an investigator working for a defense attorney? a. If the answer if yes, what was the nature of the employment? b. Would this employment affect your ability to be fair and impartial juror in this case? 11. Has any member of the jury panel ever served as a juror in the trial of a criminal case? Is there anything about your prior experience as a juror which would affect your ability to be a fair and impartial juror in this case? 12. Has any member of the jury panel ever served as a grand juror? Is there anything about your prior experience as a grand juror which would affect your ability to be a fair and impartial juror in this case? (Answers to be taken at the bench) 13. Has any member of the jury panel, or any of your relatives or close friends, been a witness to, a victim of, or arrested for and/or charged with a crime within the last 10 years? (Answers to be taken at the bench) 14. Is there any member of the jury panel who has any moral, -5- religious or philosophical convictions which would make it difficult for you to pass judgment on another person or to render a judgment in this case based solely upon the evidence presented during the trial? (Answers to be taken at the bench) 15. Are there any among you who has a hearing problem such that it would make it difficult for you to hear tape recordings, or an eyesight problem which would make it difficult to view projections of photographs, all of which may be presented as part of the evidence in this case? Do you know of any other person in the panel who has a hearing problem? (Answers to be taken at the bench) 16. Do any of you have an illness, or other medical condition which would make it difficult for you to sit as a juror? (Answers to be taken at the bench) 17. Do any of you need to take any medication which might cause drowsiness or otherwise make it difficult for you to remain alert and attentive during these proceedings? (Answers to be taken at the bench) 18. The trial may last two weeks. Is there any member of the jury panel who has an urgent or extremely important matter to attend to such that he or she would be faced with a hardship if selected for the jury in this case? (Answers to be taken at the bench) 19. Do any of you know of any reason whatever, even if not -6- covered by the Court's questions, why you could not or should not sit as a juror in this case or why you could not render a fair and impartial verdict based upon the evidence and the law as you shall hear it? (Answers to be taken at the bench) * * * * * Respectfully submitted, KENNETH L. WAINSTEIN UNITED STATES ATTORNEY _________________________________ Jeanne M. Hauch Assistant United States Attorney Transnational/Major Crimes Section Bar No. 426585 555 Fourth Street, N.W. Washington, D.C. 20530 (202) 514-5776 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was served by US Mail and by fax on counsel for the defendants, David Bos, Esq., Federal Public Defender for the District of Columbia, 625 Indiana Avenue, N.W., Suite 550, Washington, D.C. 20004, and Richard K. Gilbert, Esq., 601 Pennsylvania Avenue, N.W., Suite 900, South Building, Washington, D.C., 2004, on this _____ day of April, 2005. ____________________________________ JEANNE M. HAUCH Assistant United States Attorney