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1. Name
2. Date of Birth
3. What is your present age?
4. Where were you born?
5. Are you a citizen of the United States? (Please circle appropriate answer.
6. Can you read and understand the English language? (Please circle appropriate answer)
7. Have you ever been convicted of a crime? Do not list motor vehicle offenses
8. Have you ever been convicted of driving while intoxicated?
9. Residence (municipality only)
10. How long have you lived at your present address?
11. How long have you lived in Camden County?
12. In which town(s) in Camden County have you lived during the last ten years?
13. If you have lived less than ten years in Camden County, where else did you live in the last ten years?
14. What is your current marital status (Please check
appropriate answer and provide requested information.
Single and never married
Married and have been married for ___ years
Single, but have been married in the past for ___
years
Single, but living with non-marital mate for ___ years
Separated, have been married for ___ years
Widowed, but married in the past for ___ years
Other: ___
15. Please complete regarding your current spouse or
partner:
Is he or she (please check)
___widowed ___divorced ___ separated
16. Please complete all of the following questions
regarding your spouse/mate:
Spouse/partner's place of birth:
Spouse/partner's religion:
Spouse/partner's current employment status:
What is that person's occupation? (If that person is
retired, unemployed or disabled, what was his/her
occupation?)
17. By whom is he or she employed?
18. How long has he or she worked there?
19. What is the last level of education he/she completed and please list any degrees he/she has?
20. What are/were your parents' (and/or step-parents') occupations? (If retired or deceased, what did they do?)
21. Do you have any brothers or sisters with whom you were raised? If Yes, please list their sex, age, relationship to you and occupation.
22. Do you have any children? (Include step-children, adopted children, and foster children.) How many? What are their ages?
23. Do you have any grandchildren? How many? What are their ages?
24. If you live with others, list the people with whom you reside. List their relationship to you, sex, age, occupation/school and length of time residing together.
25. List your children with whom you do not reside. List their relationship, age, occupation/school and residence (town/state).
26. What are your hobbies, or how do you spend your free time?
27. a) Check the following which best describe your
personal educational background?
Grammar school
Some high school
High school graduate
Technical/business school
Community College
Some college
2-year college graduate
4-year college graduate
Graduate school
Other (please describe
b) While in school, what was your favorite
subject?
c. What was your least favorite subject?
28. List the degrees, if any, that you have earned and the colleges and schools you have attended and your major areas of study.
29. Have you ever taken courses in any of the following subjects? Law, criminology, medicine/health, social work, law enforcement, sociology, human behavior, journalism, criminal justice, psychology, psychiatry.
30. Are you currently attending school? If yes, what are you studying?
31. a) Since leaving school, have you attended classes,
trade schools, correspondence courses, seminars or
workshops? If yes, in what general area of study?
b) What special training or skills do you have? (Please
list any technical, medical, psychology or scientific
training and special skills acquired on the job.)
c) Have you ever worked in journalism or in the news
industry in any capacity?
d) Do you have any close friends or relatives who either
have worked or are currently working in journalism or in
the news industry in any capacity?
32. If your spouse, former spouse, or non-marital mate,
attended college, vocational or technical school, what was
his/her:
a) Major or area of study.
b) School name and location.
c) Degree(s), if any.
33. Check your current employment status (Check more than
one if appropriate):
___ Employed full-time
___ Employed part-time
___ Employed as a homemaker
___ Full-time student
___ Part-time student
___ Disabled
___ Retired (year of last employment ___)
___ Unemployed (year of last employment ___)
34. If you are currently employed, please answer the
following. If you are not currently employed, answer the
following questions with regard to your last
employment.
a) Where do (did) you work?
b) What is (was) your job title?
c) How long have (had) you been employed in this
particular position?
d) Does (did) your job include the responsibility of
hiring/firing?
e) Do (did) you supervise other people? If yes, how
many?
f) Please describe your job responsibilities.
g) If you held this job less than ten years, please list
your former jobs, for the previous ten years, and the
nature of the employment.
h) Have you ever pursued any other career/vocation?
i) Do you have a second job? If yes, please describe.
35. Are you, any family member, or close friend a present or former employee of the United States government, or any state, county, or municipal government?
36. Have you, any family member, or close friend, ever worked for or been associated with any law enforcement agency, or any of the following. If so, list the name, relationship, agency and position: Administrative Office of the Courts, Any Court Agency, Attorney General, Bureau of Alcohol, Tobacco and Firearms, CIA, County Jail, Department of Corrections, Department of Justice, District Attorney, Division of Youth and Family Services, Drug Enforcement Administration, FBI, Federal Prisons, Camden County Prosecutor's Office, Camden County Sheriff's Department, Immigration and Naturalization Service, IRS, Juvenile Delinquency Agency, Law firms, Legal Services, Medical Examiner's Office, Military Police, (Any) Municipal Police Department, N.J. State Police, Parole Board, Port Authority, Private Security Agencies, Probation Department, Public Defender's Office, Public Interest Legal Organization (e.g. ACLU), (Any) Sheriff's Department, State Prison, U.S. Attorney, U.S. Marshal, U.S. Postal Inspection Agency.
37. Have you ever had a bumper sticker on your car? If yes, what did the bumper sticker(s) say?
38. Is there anything in your background or experience which would affect how you would evaluate the testimony of law enforcement officials? If yes, please explain.
39. Do you know of any cases where you felt the police took a shortcut in their investigation? If yes, please explain.
40. Are you aware of any case(s) where you felt the police did not do a thorough job investigating a crime? If yes, please explain.
41. Have you, a family member, or close friend ever been in any branch of the armed forces of the United States (including the military reserves, National Guard, or ROTC?) If yes, please list: branch of service; dates of service; base/homeport; duty assignment; highest rank; see combat duty?; if yes, where?; were you enlisted or drafted?; special training. Have you, a family member, or close friend ever served in the military police, shore patrol, or as a corrections officer? Have you, a family member, or close friend ever participated in a court-martial or other military investigation? If yes, describe and list type of discharge.
42. While serving in the military, did you ever see one or more people who were seriously wounded? If yes, describe.
43. While serving in the military, did you ever see someone being killed or who had been killed?
44. Do you have any personal experience with, or have any feelings about, tests commonly used by law enforcement, including, but not limited to, DNA, latent fingerprint identification, trace or fiber analysis, serology, and other forensic or scientific tests? If yes, please explain.
45. a) Have you, a family member, or close friend been the
victim of ANY kind of crime, whether it was reported to
law enforcement authorities or not? If yes, list victim's
relationship to you, type of crime, whether it was
reported to police, whether anyone was caught, and the
case outcome.
b) Do you feel the criminal justice system worked properly
in regard to the case(s) listed above? If no, please
explain.
46. Have you, or any member of your family, or any close friend ever been charged with a crime or been the subject of a criminal investigation?
47. If Yes: a) Who and how many times? b) Was the matter resolved to your satisfaction through the criminal justice system?
48. For each arrest, please describe what the charge(s) was, whether there was a jury trial, and what the outcome was?
49. Have you ever known anyone who was the victim of homicide? (Homicide includes murder, manslaughter, vehicular homicide, or death by auto.) If yes, state: a) Relationship to you. b) When did it occur. c) Where did it occur. d) Was anyone ever charged? e) What was the outcome of the case? f) What are your feelings concerning this outcome?
50. Have you, any family member, or close friend ever been: a) A party to a lawsuit? b) A witness in court?
51. Have you ever served as a grand juror? If yes, when? Where?
52. Have you ever served as a petit (trial) juror before?
If yes, how many times? If yes, when? Where? If yes,
please answer these questions:
a) Was the case a civil or criminal case?
b) What type of case was it? E.g. If criminal --
robbery burglary. If civil -- malpractice, slip and
fall.
c) Did you deliberate or serve as an alternate?
d) Did you reach a verdict?
e) Did you have difficulty understanding or following
the judge's instructions?
f) Were you ever a foreperson?
g) Would any of your previous jury service affect your
ability to serve as a juror in this case?
h) Was there anything about your prior jury service in
any case which would make it difficult for you to sit as a
juror in this case?
53. As to the organizations below with which you are
familiar, please indicate which have goals or purposes
with which you agree or with which you sympathize. Also
indicate those with which you disagree, or those about
which your feelings are neutral. If you are unaware of the
goals or purposes of an organization, please so indicate.
Answer this question regardless of whether or not you are
a member of the particular organization. You may add
additional organizations in the blank spaces at the bottom
of the list: American Civil Liberties Union, White Aryan
Nation, B'Nai B'rith, Greenpeace, Handgun Control Inc., Ku
Klux Klan, Moral Majority, Mothers Against Drunk Driving,
NAACP, National Jewish Anti-Defamation League, National
Organization for Women, National Pro-Choice, National
Rifle Association, National Right to Life, Jewish Defense
League.
54. List any civic, social, charitable, professional, political, fraternal, or union organizations to which you now belong or did belong during the past ten years. Also, list any organizations for which you do volunteer work. Indicate if you have ever served as an officer, board member, trustee, or position of authority in any of these organizations.
55. Are you a member of any group or organization that is concerned with racial/ethnic issues? If yes, please identify the groups.
56. Are you a member of any private club, civic, professional or fraternal organization which limits its membership on the basis of ethnic origin or religion? If yes, please identify the group or organization.
57. As a part of your service on this case, the Court will order you not to read, listen to or watch any accounts of this case reported by television, radio or other news media. Will you have any difficulty following this order?
58. If you are selected as a trial juror in this case, the Court will order you not to discuss the case with anyone unless and until permitted to do so by the Court. Will you have any difficulty in following this order?
59. If you are selected as a trial juror in this case, the Court will order that you not request, accept or discuss with any person receiving or accepting, any payment or benefit in consideration for supplying any information regarding this trial. Will you have any difficulty following this order?
60. What do you think about jurors appearing on talk shows after serving on a criminal trial jury?
61. Have you watched a juror or jurors in a particular case talk on television about their experiences on the jury? If Yes, what do you recall and what was your impression of his/her experience?
62. Have you listened on the radio to a juror or jurors in a particular case talk about their experience on the jury? If Yes, what do you recall and what was your impression of his/her experience?
63. Have you read about a juror's experience on a particular case in a newspaper or magazine? If Yes, what do you recall and what was your impression of his/her experience?
64. What do you think about a juror writing a book about his/her experience on a case?
65. Have you read any books or articles about a juror's experience on a jury? If Yes, please explain.
66. Because this case has received extensive publicity, many, if not all, of you will have heard and/or read something about this case at some time. It is vitally important that you truthfully answer the following questions concerning what you have learned about this case from the media. There are no right or wrong answers. There should only be truthful and forthright answers.
67. Please indicate from which of these sources you have learned about this case (check as many as apply): Television, Tabloids, Magazines, Books, Radio, Newspapers, Have overheard other people discuss it, Have had conversations with other people.
68. If you learned about this case from television, radio,
newspapers, or magazines, please check all areas listed
below which describe your exposure to each:
Television: CBS News, Ch. 3; ABC News, Ch. 6; FOX News,
Ch. 7; CN8, Ch. 8; NBC News, Ch. 10.
Newspapers: Philadelphia Inquirer, Philadelphia Daily
News, Courier-Post.
69. a) Have you seen television coverage, other than
appearances in court, of any of the lawyers for the
defense?
b) If Yes, please describe what you recall.
c) If yes, what was your reaction to what you observed?
70. a) Have you observed television coverage, other than
appearances in court, of any of the lawyers for the
prosecution in this case?
b) If Yes, please describe what you recall.
c) If yes, what was your reaction to what you observed?
71. Have you watched on television any portion of any of the court hearings which have been held since the arrest of the defendant on Sept. 10, 1998? If Yes, what do you recall about those hearings?
72. Have you watched any television shows besides the news which had stories regarding this case?
73. If yes, explain which show(s) and what you recall about them.
74. Have you listened to radio talk shows about the case?
75. If yes, explain which show(s) and what you recall about them.
76. What impressions or opinions, if any, have you formed as a result of the television, radio or newspaper coverage of this case?
77. If, as a juror on this case, you heard evidence that was in conflict with information you learned from the media, how would you resolve that conflict?
78. Do you believe that the news media generally gives a complete and accurate unbiased account of events? Please explain your view.
79. Which of the following best describes how you would
describe media coverage of this case overall?
___ Biased in favor of the prosecution.
___ Biased in favor of the defense.
___ Basically fair to both sides.
80. This case will be closely followed by local, state, national electronic and print media. What is your reaction to this?
81. On average, how often have you talked to anyone about this case: daily; once every other day or so; a couple times a week; once a week; once a month; almost never; never.
81. If you have discussed this case with others, do most of these people think that Fred J. Neulander is: not guilty; probably not guilty; not sure; probably guilty; guilty.
83. Has anyone directly or indirectly tried to contact you about this case?
84. Do you have specific health or psychological problems that might make it difficult for you to sit as a juror on a case which may last approximately 4 to 5 weeks?
85. Is there any other reason which would make it difficult for you to sit as a juror on a case which may last approximately 4 to 5 weeks?
86. The defendant in this case is Fred Neulander.
a) Do you know Fred Neulander?
b) Do you know any members of his family?
c) Do you have any family members or close friends that
know Fred Neulander?
d) If so, how are they acquainted with him?
e) For any reason, would it be difficult or impossible to
judge Fred Neulander fairly?
87. The victim in this case is Carol Neulander.
a) Did you know the victim?
b) Do you know any members of her family?
c) Do you have any family members or close friends that
knew Carol Neulander or any members of her family?
d) If yes, who are they acquainted with and how?
88. Representing Fred Neulander will be the following attorney(s): Jeffrey Zucker and Denis Wixted. Do you, any family member, or close friend know these attorneys, any members of their families or any of their current or past employees? Have you, any family members or close friends ever been represented by these attorneys or by any lawyer in their office?
89. Representing the State of New Jersey will be the following assistant prosecutor: James P. Lynch. Do you, any family members, or close friends know First Assistant Prosecutor James Lynch or any members of his family or any current or former members of his office? Have you, any relatives or close friends ever been represented by the Assistant Prosecutor or by any lawyer in his office?
90. Do you know Judge Linda G. Baxter, formerly known as Judge Linda G. Rosenzweig, or any member of her staff?
91. a) Fred Neulander is an ordained rabbi. He was the
founder and longtime senior rabbi at a synagogue in Cherry
Hill known as Congregation M'Kor Shalom.
b) Are you or any family members or close friends current
or former members of Congregation M'Kor Shalom? If so,
give details.
c) Do you believe that religious leader should be judged
by a different standard than other persons?
d) Do you believe that the presumption of innocence is
greater where the defendant is a religious leader?
e) Would it be difficult or impossible for you to convict
a religious leader of murder, even if the evidence
convinces you of his guilt beyond a reasonable doubt?
f) In this case, you will be hearing evidence of
statements made by Fred Neulander. Do you believe a
religious leader is more likely than other people to tell
the truth?
g) In this case, Fred Neulander may choose to take the
stand and answer questions under oath in his own defense.
Would you be more inclined to believe his testimony
because he is a religious leader?
h) If Fred Neulander is convicted of murder, would it be
difficult or impossible to vote for capital punishment
because of his status as a religious leader?
92. Because this is a criminal case, it is the law that Fred Neulander is presumed innocent throughout the entire trial and even into the jury deliberations until such a time as the jury may find him guilty beyond a reasonable doubt. Can you accept this rule of law and follow it in your deliberations?
93. Because this is a criminal case, it is the law that the State has the burden to prove the guilt of Fred Neulander, beyond a reasonable doubt. The burden of proof never shifts and no burden with respect to proof is imposed upon Fred Neulander. Fred Neulander is not obliged to prove that he is innocent. Can you accept this rule of law and follow it in your deliberations?
94. Because this is a criminal case, it is the rule of law that Fred Neulander has no obligation to testify. If Fred Neulander exercises his right not to testify, the jury may not draw an inference of guilty from his silence or use that failure to testify in any way in their deliberations. Can you accept this rule of law and follow it in your deliberations?
95. The following are statements of law. Please state your
personal beliefs regarding each of these statements. Do
you agree strongly, agree, have no opinion, disagree or
disagree strongly?
a) Fred Neulander possesses a presumption of innocence
throughout the trial.
b) The prosecution's burden is to prove guilt beyond a
reasonable doubt. If the prosecution fails to do so, you
must find Fred Neulander not guilty.
c) A county grand jury has charged Fred Neulander in an
indictment. What that means is that the prosecutor has
presented certain testimony and evidence. The fact that
Fred Neulander was indicted by the grand jury is not
evidence of his guilt and no negative inference may be
drawn from the fact that he was indicted.
d) Law enforcement officers or agents may be called to
testify in this case. As far as their credibility is
concerned, they are under the same level of scrutiny as
anyone else appearing in this case as a witness. Law
enforcement officers or agents are not entitled to greater
or lesser weight on the issue of credibility merely
because they are law enforcement officers.
e) The job of determining the truth of what a witness
testifies to at trial is to be accomplished by, among
other things, observing the witness while he testifies,
evaluating any information which supports or attacks
either side, and applying common sense and experience to
draw a conclusion about the witness' truthfulness.
f) The verdict you reach in this case must come only from
the evidence and testimony presented in court. It may not
be based upon information you see, hear or learn from any
other source (i.e. other people, television, newspapers,
radio, etc.)
96. Please state your personal belief regarding each
statement. Do you agree strongly, agree, have no opinion,
disagree or disagree strongly?
a) "A defendant is innocent until proven guilty beyond a
reasonable doubt."
b) "If the prosecution goes to the trouble of bringing
someone to trial, the person is probably guilty."
c) "The testimony of law enforcement officers or agents is
not entitled to any greater or lesser weight merely
because they are law enforcement officers or agents."
d) "Regardless of what the law says, a defendant in a
criminal trial should prove his or her innocence."
e) "People who make more money are treated better by our
court system than those people who make less."
97. Do you believe that a defendant in a criminal case should testify or produce some evidence to prove that he or she is not guilty? Please explain why.
98. What are your thoughts, feelings or opinions of criminals who agree to testify for the prosecution?
99. How do you feel about the government reducing a criminal's sentence in exchange for their testimony?
100. Do you know anyone who has been arrested or convicted and then has agreed to be a witness for the government? If yes, please explain.
101. Do you believe that you would be a good juror for this case? Please explain.
102. Would the nature of the charge, murder, affect your ability to be a fair an impartial juror?
103. If you are chosen as a juror in this case, you will
hear evidence about the death of the victim. You may also
see pictures of the victim after she died. Will you be
able to listen to the testimony about the victim's
death?
a) Will you be able to look objectively at descriptive
pictures of the victim after her death?
b) After listening to the testimony and looking at the
photographs, will you set your emotions aside and fairly
and impartially decide this case based solely on the
evidence presented to you and the instructions provided by
the court?
104. How do you feel about Jewish people in general?
105. Fred Neulander is Jewish. He was the Rabbi of M'Kor Shalom synagogue in Cherry Hill and functioned as a religious leader. Would that fact affect your ability to be fair and impartial as to the issues in this case?
106. Have you ever had a bad or negative experience with someone who is Jewish? Please explain.
107. Do you have any friends or relatives who are Jewish?
108. There may be some people who have strong feelings about Jewish people. Do you believe that you would be more fair to Fred Neulander if he were not Jewish.
109. Do you believe that a Rabbi or other religious leader should be held to a higher standard of personal conduct than other people?
110. In this case, the issue of marital infidelity by Fred Neulander will be presented. Do you believe that the unfaithfulness of Fred Neulander would make him more likely to commit an offense against his wife? Please explain your answer. Or would you treat the issue of marital infidelity as you would any other piece of evidence and give it whatever weight, if any, you deem it is entitled?
111. Do you have an opinion, impressions, or feelings as to the guilt or innocence of Fred Neulander in this case?
112. Have you ever expressed an opinion or impression, or feelings about the guilt or innocence of Fred Neulander before today?
113. Have you read or heard about any other similar cases during the past two years? If yes, would the nature of the other case(s) or anything you have heard about the other case(s) interfere with your being a fair and impartial juror in this case?
114. What are your general feelings or opinions about psychiatry and psychology?
115. Have you ever studied psychiatry or psychology?
116. Have you ever read any articles or books about psychiatry or psychology?
117. Have you, any family member or a close friend ever sought the assistance of a psychiatrist, psychologist or counselor to help with a personal problem? If yes, do you think this experience was helpful to you, the family member, or close friend?
118. Do you have an opinion about the use of psychiatric or psychological expert(s) or evidence in criminal trials? If yes, please explain.
119. Would you tend to give greater weight to the testimony of a psychiatrist/psychologist just because he/she is a psychiatrist/psychologist?
120. Would you tend to give lesser weight to the testimony of a psychiatrist/psychologist just because he/she is a psychiatrist/psychologist?
121. Is there anything in your background or experience which would affect how you would evaluate the testimony of a psychiatrist/psychologist? If yes, please explain.
122. Would you view psychiatric or psychological testimony with an open mind?
123. Do you think you would be able to fairly and impartially decide a case in which one of the issues may involve evaluating psychiatric or psychological testimony?
124. As you may know, there are certain labels or stereotypes which are used by some people to describe persons of various racial, religious or ethnic groups. Have you, a member of your family or a close friend, ever been subjected to such labels or stereotypes based on racial, religious or ethnic heritage? If yes, please describe.
125. Has anyone ever acted in a way that you thought showed prejudice against you? Please describe the situation.
126. Have you ever seen or witnessed behavior that seemed to you to be an example of racial or religious prejudice? If yes, where were you (town, state, country) and please describe that situation.
127. Have you, a family member, or a a close friend ever gone through a separation or a divorce?
128. What are your feelings and opinions about divorce?
129. Have you, a family member, or a close friend ever been the victim of physical or emotional abuse, whether reported or not, during a relationship?
130. Have you, a family member, or close friend ever been accused of physically or emotionally abusing a spouse or partner in a relationship?
131. Have you, a family member, or close friend ever applied for or obtained a domestic violence restraining order?
132. Have you ever been in a position of being in fear for your life because of the actions of another human being? If yes, please tell us about that.
133. Have you, a family member, or close friend ever had a domestic violence restraining order issued against you?
134. a) Do you think you would be able to fairly and
impartially decide a case in which you may hear testimony
or evidence involving the alleged murder of a wife by her
husband?
b) Would such testimony or evidence affect your ability to
follow the instructions of the court?
135. There has been a lot of publicity lately about domestic abuse. Have you read or seen any of these stories? If yes, pleas tell us where and when.
136. Have you, any member of your family, or close friends ever worked, or volunteered to work at a crisis line, rape crisis center, battered women's shelter, or similar place? If so, please tell us where and when.
137. Have you, a family member, or close friend ever experienced alcohol or drug addiction? What happened as a result?
138. Have you, a family member, or close friend ever received any alcohol or drug treatment?
139. Do you feel that a witness's use of alcohol or drugs should be a consideration in a homicide trial?
140. a) Do you think you would be able to fairly and
impartially decide a case in which you may hear testimony
or evidence involving use of alcohol and/or drugs?
b) Would such testimony or evidence affect your ability to
follow the instructions of the court?
141. What is your religion?
142. Were you raised in a specific religion? Which one?
143. Do you still belong to the religion in which you were raised?
144. How often do you attend services (please circle): daily, yearly, weekly, monthly, never, only on religious holidays, other.
145. How important would you say religion is in your life?
146. How do you feel about inter-ethnic or inter-religious marriage?
147. How would you feel if a close family member or relative married someone of a different ethnicity or religion: would favor it; would not oppose it; would oppose it. Please explain
148. Have you ever dated a person of a different ethnicity or religion? If yes, how did you feel about it.
149. Is there any religious or ethnic group that you do not feel comfortable being around? If yes, please explain.
150. What is your reaction when you hear a racial/ethnic slur or joke?
151. What role do you think religion should play in the criminal justice system?
152. In what ways, if any, would your religious views affect your service as a juror in a death penalty case?
153. Does your religion have a teaching, policy, or doctrine regarding the death penalty? If so, please explain.
154. Would anything about your religious beliefs make it difficult for you to sit in judgment of another person?
155. Do you have strong feelings about jurors taking an oath by swearing or affirming to God?
156. Do you have any bias, prejudice, sympathy, or resentment for Fred Neulander, Carol Neulander, the attorneys, or any of the proposed witnesses because of his/her religion?
157. If a witness who was close to the victim testifies regarding the victim's character and background will such testimony affect your ability to follow the instructions of the court, or render a fair and impartial verdict?
158. If a witness who was close to the victim testifies regarding the impact of the crime on the victim's survivors, will such testimony affect your ability to follow the instructions of the court to render a fair and impartial verdict?
159. Please explain your views on the death penalty.
160. For what types of crimes, if any, do you feel the imposition of the death penalty is appropriate.
161. Are there circumstances that would prompt you to automatically vote for the imposition of the death penalty? Please explain.
162. Are there circumstances that would prompt you to automatically vote against the death penalty? Please explain.
163. Are there any circumstances which would make impossible your consideration and evaluation of mitigating factors presented on behalf of Fred Neulander? If yes, please explain.
164. In making the determination whether Fred Neulander should receive the death penalty or, alternatively, a period of imprisonment as described above, what would you want to know about Fred Neulander?
165. Do you believe in the biblical adage, "an eye for an eye"? Is your belief based on a religious conviction? Please explain.
166. Do you believe that a defendant should have to prove that he/she does not deserve the death penalty in order to impose a life sentence? Please explain your answer.
167. Is the cost to the taxpayers of the State of New Jersey for housing an inmate for a life sentence a concern to you? Please explain your answer.
168. Would you be concerned about the opinions of your
family, friends, co-workers or the general public should
you serve as a juror in this case and not:
a) find Fred Neulander guilty?
b) impose the death penalty?
169. Do you think that the following prison term is a sufficiently harsh sentence for a person who has been found guilty of the crime of murder: Between 30 years and life imprisonment of which 30 years must be served before Fred Neulander is eligible for parole?
170. Are the following punishment and the imposition of the death penalty equal punishments in your mind: Between 30 years and life imprisonment of which 30 years must be served before Fred Neulander is eligible for parole?
171. Do you believe that because the State seeks the death penalty as a punishment, Fred Neulander is more likely to be guilty of the offense?
172. Is there any matter which you feel you should call to the court's attention which may have some bearing on your qualifications as a juror or which you feel may prevent you from rendering a fair and impartial verdict?
173. Have you formed an opinion about this case based upon completing this questionnaire? Is yes, please explain.
174. Attached to the questionnaire is a list of the prospective or potential witnesses who may testify or whose names may be mentioned in this case. Please review the list carefully and circle the names of anyone whom you know in any way.
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