CAMDEN -- Defense attorneys for Rabbi Fred J. Neulander, who is accused of ordering his wife's murder, filed a brief Thursday supporting their request that his trial be heard by jurors from outside Camden County.

In the brief, the attorneys say an informal telephone survey suggests many local residents believe Neulander is guilty of arranging the Nov. 1, 1994, killing of his wife, Carol. The lawyers also argue widespread publicity about the murder threatens the rabbi's right to a fair trial.

No date has been set for the trial, in which Neulander could face the death penalty if convicted. Two men have pleaded guilty to carrying out the murder, which they said was at Neulander's direction.

Superior Court Presiding Criminal Judge Linda Rosenzweig is set to rule on the venue question on Nov. 9.

Under court rules, she can either move the trial to another county or select jurors from another county who would be brought to Camden for the trial.

The brief does not suggest a county from which jurors could be selected. It is unlikely the trial would begin within a year.

The brief, with language as colorful as news accounts of the Neulander case, includes results of an informal survey conducted over three weekends in July by Neulander attorney Jeffrey Zucker.

The random calls showed that 88 percent of 163 respondents had heard of the case and 85 percent believed Neulander is guilty. Eighty percent of those surveyed said they would be unable to put aside what they had read and heard about the case to base a verdict on evidence submitted at trial, Zucker said.

Co-counsel Dennis Wixted, who drafted the brief, said the ``tidal wave of publicity pounding the shoreline of Camden County" creates a risk of jurors hoping to gain celebrity status. Wixted said he fears jurors could lie when questioned about their ability to remain impartial.

Wixted argues that recent Supreme Court cases, notably covering convictions of Ambrose Harris, who murdered a young artist in Trenton and whose trial for the stomping death of Robert ``Mudman'' Simon was moved from Mercer County to Monmouth County, and Jesse Timmendequas, who murdered a young neighbor in Hamilton, Mercer County, after a sexual assault, suggest lenient rulings by trial court judges facing change-of-venue motions.

While Neulander is not ``deemed despicable in the eyes of the average citizen,'' as both Ambrose and Timmendequas were, he is considered a celebrity, Wixted writes.

In part, that celebrity status came from his position as leader of one of the area's largest synagogues. The Neulander case also has made headlines as authorities contended marital infidelity was a motive for the killing and after the surprise confession last spring by a Neulander associate, former private investigator Len Jenoff.

Jenoff, and an accomplice, Paul Daniels of Pennsauken, have pleaded guilty to aggravated manslaughter.