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How many of you have felt it necessary to purchase a firearm to protect yourselves or your family at home or in the workplace?

How many of you have learned about the allegations against my client through television, radio, newspapers, social media, the Internet or any other source? Based on what you have initially heard about this case, have you made up your mind as to my client’s guilt or innocence?

Have you formed or expressed an opinion about my client’s guilt or innocence based on what you have heard?

What opinions have you formed or expressed?

If I were able to provide you evidence that your opinion is wrong, would you have an open mind and be willing to presume my client innocent until proven guilty by the State or Government beyond any reasonable doubt?

Have any of you been in fear of death or serious physical harm by an armed individual?

The law in this state allows citizens to use deadly force against an aggressor when he/she believes it is reasonably necessary to protect him/herself from imminent bodily harm or serious physical injury. Do any of you disagree with the law? Would any of you be unwilling to follow the law?

The law in our state is clear that my client cannot be convicted in a case of this nature unless all twelve of you unanimously believe beyond a reasonable doubt that my client did not act in self defense, as we just discussed. Are there any of you who, for any reason, could not follow the most important rule of law that will govern this case?”

I do not want to appropriate undue space in your publication from other attorneys’ valuable contributions on this subject. I would ask several pages worth of questions along these lines. The point of this exercise is to identify jurors who are biased against my client and ask the type of questions that would lead to either them being stricken from the panel for cause due to their bias in the case or to justify a peremptory challenge so there would be no surprise later.

An experienced trial attorney knows that the theory of the case must be carefully woven through the art of persuasion from the jury selection process through closing argument.

Within the bounds of the law, the attorney should educate the jury in voir dire about the alleged facts involving the case. It is essential to find out what the jurors know and believe about the case before it starts. It is imperative to educate the jurors about the particular self-defense law that is applicable in the state in which the case is tried.

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