Jury Pool in Sean “Diddy” Combs Trial Will Be Asked These Questions by Judge During Voir Dire

On the first day of Sean “Diddy” Combs’ trial on federal sex trafficking and racketeering charges, 12 jurors are being selected to hear the case against the rap mogul and his defense. In a process known as voir dire (“to speak the truth”), Judge Arun Subramanian is asking a set of questions submitted from both sides of prospective jurors at the Daniel Patrick Moynihan Courthouse in Lower Manhattan this week.

One by one, jurors are being asked questions by the judge as the pool is gradually whittled down to 45 potentials, who can then be dismissed by the defense or the prosecution, with no reason given. These include whether they had heard news about allegations against the hip-hop mogul, seen the CNN video of Combs assaulting a woman in a hotel hallway or even heard any of the baby oil jokes after feds raided his homes and removed evidence (one potential juror said he had).

Another potential juror was dismissed Monday by Subramanian when she indicated that an image of Combs standing above a woman on the floor “could be damning evidence.” However, another remained when she said she’d seen a clip of that incident but told the judge she’d be a “blank slate” going into the trial, according to reporting from inside the courtroom from MSN.

Here’s a look at what the defense sought to ask potential jurors, followed by what the prosecution sought that the judge ask the jury pool as he selects the 12 men and women and six alternates. 

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Pursuant to the Court’s scheduling order (ECF 125), the defense’s proposed voir dire questions on behalf of defendant Sean Combs are listed below: 

1. What is your age? 

2. What is your sex? 

3. What is your gender identity? 

4. In what city and county do you live? 

5. Who, if anyone, do you live with? 

6. If you are married or in a relationship, what is your spouse or partner’s occupation and employer? a. How long have they worked for that employer or been in that occupation? b. What are their job responsibilities? 

7. Do you have children? a. If so, what are their ages? b. If you have adult children, what, if anything, do they do for work? 

8. Are you currently working?
a. Who is your current (or most recent) employer and what is your job title?
b. If not, when was the last time you worked and please describe your most recent employment? What were your specific duties at your job?
c. If you are working, what do you do for a living? What are your specific duties at your job?
d. How would you describe your job responsibilities?
e. Do you manage or supervise others as a part of your job? 

9. What is the highest level of education you have completed, and if you have any college or postgraduate degrees, what was your degree or area of study? 

10. I am going to read you a list of occupational areas. Please tell me if you or someone you are very close to has any training, experience, or specialized knowledge in that area, and explain your/their experience: 

a. Business 
b. Sexual Assault Training 
c. Sexual Harassment Training 
d. Domestic Violence Training 
e. Case Psychiatry/Psychology 
f. Security Services 
g. Addiction Treatment or Counseling 
h. Finance 
i. Law or Law Enforcement 

11. What clubs, groups, or organizations do you belong to or regularly participate in (for example, church groups, professional organizations, volunteer activities, victims’ rights groups, etc.):? a. If you have a spouse or partner, what clubs, groups, or organizations does your spouse or partner belong to or regularly participate in? 

12. What do you do in your free time? What are your hobbies or interests outside of work and family? 

13. Do you use any social media platforms? If yes, which ones? 

14. How do you get your news? 

a. What, if any, newspapers, magazines, websites, online news services or publications do you read most often? 
b. Do you listen to any podcasts? If so, which ones? 

15. I am going to read three group-decision-making styles, and I’d like you to tell me which one comes closest to the way you make decisions:  

Participate in the discussion and try to help build a consensus. Listen and follow what you think the majority favors 

16. Do you believe you make most decisions based on intuition or the examination of facts? 

17. Do you have any personal experiences or opinions about drug or alcohol use or addiction? a. If yes, what is that experience? b. You are going to hear about drug and illegal alcohol use in this trial. Is that going to be difficult for you based on your experience? 

18. The defendant in this case is a wealthy celebrity. Do you have any opinions regarding wealthy individuals that would affect your ability to serve as a fair and impartial juror in this case? 

a. Do you believe that wealthy people get away with things that the less wealthy do not? 

19. What kind of music do you like? 

a. How often do you listen to music? 
b. Do you have an opinion about the hip-hop rap music industry or artists in that genre? 
c. If so, please tell us what it is.

A. The Charges

This is a criminal case. To help you understand the reason for the questions I’ll be asking you, I want to tell you briefly about the charges. The defendant, Sean Combs, a/k/a “Puff Daddy,”a/k/a “P. Diddy,” a/k/a “Diddy,” a/k/a “PD,” a/k/a “Love,” has been charged with the commissionof certain federal crimes in a document called an Indictment filed by a grand jury sitting in this District.

The Indictment is not evidence itself. It simply contains the charges that the Government is required to prove beyond a reasonable doubt. I will briefly summarize the charges in this casein order to give you a legal framework as you listen to the evidence for what you will ultimatelybe asked to do at the end of the trial.

The Indictment contains five counts or charges:

Count One charges that, from at least in or about 2004 through in or about 2024, the defendant participated in a racketeering conspiracy during which he agreed with other employees and associates of his businesses to commit kidnapping, arson, bribery of a witness, obstruction ofjustice, drug distribution, forced labor, sex trafficking, and transportation for purposes of engaging in prostitution.

Count Two charges the defendant with sex trafficking an adult female victim through force,fraud, and coercion between in or about 2009 and in or about 2018.

Count Three charges the defendant with transporting that female victim and malecommercial sex workers to engage in prostitution between in or about 2009 and in or about 2018.

Count Four charges the defendant with sex trafficking a second adult female victim throughforce, fraud, and coercion between in or about 2021 and in or about 2024.

Count Five charges the defendant with transporting that second female victim and male commercial sex workers to engage in prostitution between in or about 2021 and in or about 2024.

B. General Ability to Serve

1. Would you have any difficulty following my instructions with respect to thefundamental principles I have just outlined?

2. Do you have any personal knowledge of the charges in the Indictment as I have just described them beyond what you have already noted in your questionnaire?

3. It is not a particularly pleasant duty to find another individual guilty of committinga crime. If the evidence established a defendant’s guilt beyond a reasonable doubt, would you be willing to share

4. unable to render a guilty verdict for reasons unrelated to the law and the evidence? And if theevidence failed to establish a defendant’s guilt beyond a reasonable doubt, would you be unableto render a not guilty verdict for reasons unrelated to the law and the evidence?

5. Is there any reason you could not view and decide fairly and impartially a caseinvolving the charges as I have described it that you have not already noted in your questionnaire?

C. Knowledge of the Trial Participants

6. As noted in your questionnaire, the defendant, Sean Combs, is represented by Marc Agnifilo, Teny Geragos, Anna Estevao, Alexandra Shapiro, Jason Driscoll, and Brian Steel [They will be assisted by the list here]. [ Please ask them to stand.] Seeing them here today, do you know any of these individuals?

7. Similarly, as noted in your questionnaire, the prosecution, referred to here as the Government, is represented here, as in all cases where it is a party before this Court, by the United States Attorney for the Southern District of New York, Jay Clayton. 

The conduct of the trial will be in the immediate charge of Assistant United States Attorneys Maurene Comey, Meredith Foster, Emily Johnson, Christy Slavik, Madison Smyser, and Mitzi Steiner. They will be assisted by HSI Special Agent Sean Quinn, HSI Special Agent Kiera Murphy, and HSI Task Force Officer Phil Adaszewski, as well as Shannon Becker, Lucy Gavin, and Chanel Foster, paralegal specialists in the U.S. Attorney’s Office. [Please ask them to stand]. Seeing them here today, do you know any of those individuals?

8. Are you familiar with anyone else present in the courtroom, including all court personnel or myself? Did you recognize any of your fellow jurors in the jury assembly room?

9. I will now hand you a list of names of individuals who may be mentioned during the trial, or who may be witnesses in this case. Please read this list to yourself, and please do not say any of the names out loud:

[Numbered list of names to be supplied, including true names of victims testifying under pseudonym]

Please answer the following questions referring only to the number next to the relevant name without saying any name out loud.

10. Do any of you know any of the people on that list personally? Have you had any dealings, directly or indirectly, with any of these individuals? To your knowledge, have any of your relatives, friends, or associates had any dealings with any of these individuals?

D. Knowledge of Locations

Do you have any familiarity with any of the following places that may be mentioned during the course of the trial?

E. Relationship With and Views Regarding Government and Defense

11. Have you ever studied or practiced law or worked in any capacity for a law office?

12. Have you or has a relative or close friend worked for or with any federal, state, or local law enforcement agency, such as the United States Attorney’s Office for the Southern District of New York or the Department of Homeland Security Homeland Security Investigations (“HSI”), or the New York City Police Department (“NYPD”) in any capacity, including as a contractor?

13. Have you or has a relative or close friend done work for or been associated with a criminal defense lawyer or private investigator?

14. Have you ever been involved, or do you expect to become involved, in any legal action or dispute with the United States or any agency, officer, or employee of the United States?

15. Do you have any views about the United States Attorney’s Office for the Southern District of New York, HSI, the NYPD, or any other law enforcement agency that would interfere with your ability to be fair and impartial?

16. Do you have any views about criminal defense attorneys that would interfere with your ability to be fair and impartial?

F. Experience With and Opinions of Legal Proceedings and Relevant Topics

17. Have you, or has any relative or close friend, ever participated in a state or federal court case, whether criminal or civil, as a witness, plaintiff, or defendant? If so, what kind of case?

If so, what was your role in that case?

If so, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

18. Have you or any relative or close friend ever been involved or appeared as a witness in any investigation by a federal or state grand jury or by a congressional or state legislative committee, licensing authority, or governmental agency, or been questioned in any matter by any federal, state, or local law enforcement agency? If so, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

19. Have you, or has any relative or close friend, ever been subpoenaed for any inquiry or investigation? If so, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

20. Have you, or has any relative or close friend, ever been the subject of any investigation or accusation by any grand jury, state or federal, or any other investigation? If so, is there anything about that experience that would prevent you from acting as a fair and impartial juror in this case?

21. Have you, or any of your relatives or close friends, ever been a victim of a crime? If yes, please describe the circumstances, including the type of crime, when it happened, and the

outcome of any law enforcement action. Is there anything about that experience that could affect your ability to be fair and impartial in this case?

22. You may hear evidence in this case relating to acts of violence, including intimate partner violence and other assaults. Do you have any feelings, beliefs, or experiences relating to that aspect of the case that could affect your ability to be fair and impartial in this case?

23. You may hear evidence in this case relating to sexual assault, including rape. Do you have any feelings, beliefs, or experiences relating to that aspect of the case that could affect your ability to be fair and impartial in this case?

24. You may hear evidence in this case relating to the payment of commercial sex workers in exchange for sex. Do you have any feelings, beliefs, or experiences relating to prostitution and the enforcement of laws around prostitution that could affect your ability to be fair and impartial in this case?

25. [The Government notes that this question may be omitted depending on the outcome of pending motion practices]

26. You may hear evidence relating to firearms. Do you have any feelings, beliefs, or experiences about guns and the enforcement of gun laws that could affect your ability to be fair and impartial in this case?