Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:03-cv-01009-SRU

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Filed 04/07/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOSEPH ATTIAS & HAIM ATTIAS Plaintiffs : : : PATRONS MUTUAL INSURANCE COMPANY OF CONNECTICUT Defendant : : : APRIL 7, 2006 CIVIL NO. 3:03 CV 01009 (SRU)

PLAINTIFF'S PROPOSED VOIR DIRE QUESTIONS 1. In this case, the plaintiffs Hiam and Joseph Attias are suing their insurance

company for refusing to pay on a fire loss claim. Is there any reason why you would have difficulty being completely neutral and fair in deciding this case if you are chosen to serve on the jury? 2. of case? 3. If the plaintiffs prove their claims, can you agree to award fair, just and Is there anyone here who would prefer not to sit on a jury concerning this type

reasonable monetary damages for the wrongful actions of the defendant insurance company? 4. Have you or anyone close to you ever been employed as a policeman or by any

law enforcement agency in any capacity? If so, please explain. 5. Have you or anyone close to you ever been employed in the insurance

Case 3:03-cv-01009-SRU

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industry in any capacity? If so please explain? 6. 7. Have you or your spouse ever trained or worked as a Public Adjuster?

Has anyone here or anyone close to you ever been employed by any other State, Federal

or local Governmental unit? If so when, by whom and in what capacity? 8. Do you know or have you read anything or heard anything about this case, the plaintiffs

or the defendant, or any of the lawyers involved in the case? 9. When you read or heard about other civil suits, did you form any opinions as to the

validity or invalidity of the claim, the fairness of the verdict or the amount of damages awarded? 10. Has anyone here ever served as an appointed or elected official of state, city or local Government? 11. Have you or your spouse ever been a landlord or worked in property management? 12. Has anyone here, your family members or close friends ever been employed as an attorney or work in any attorney's office? 13. Would the fact that the defendant is an insurance company cause you to tend to favor one side or the other in this case or in regard to the evidence, which may be presented? 14. Would the fact that the plaintiffs Hiam and Joseph Attias are not US citizens but are citizens of Israel cause you to tend to favor one side or the other in this case or in regard to the evidence, which may be presented 15. Is there any member of this panel who knows any other member of this panel,

other than through this jury selection process today?

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16. business? 17.

Have you or your spouse ever been self-employed? If so, in what type of

Have you or anyone close to you been sued or brought suit civilly, either

directly or in a representative capacity? If so, when, and what was the general nature of the claim and were you satisfied by the manner in which the civil justice system worked? 18. At the end of the trial, the court instructs the jury on certain matters of law. As

a juror, you would be required to apply the law as the court explains it, even though you may not agree with the law. If you should find yourself in disagreement with the law as instructed by court, would it be difficult for you to faithfully apply the law as the court explains? 19. If you were selected as a juror in this case and during the course of the trial or

deliberations you become aware of a lack of fairness, or you became aware of any partiality or bias on your part or any other juror's part, would you have difficulty making that situation known to the court? 20. What are your hobbies and activities and what newspapers and magazines do

you regularly read? 21. 22. 23. 24. 25. Have you or your spouse ever worked for a mortgage company or bank?

Have you or your spouse ever worked for or been trained as an appraiser? Have you or your spouse ever worked as a contractor? Do you have any strong opinions regarding people who bring lawsuits? Are you active in any organizations, whether social, political, professional or

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regarding your religious faith? 26. Do you own your own home or any investment properties?

THE PLAINTIFFS,

BY: Cheryl E. Heffernan Farver & Heffernan 2858 Old Dixwell Avenue Hamden, Connecticut 06518 Telephone: 203-230-2500 Facsimile: 203-288-4702 Fed Bar No.: CT 06473

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