Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:02-cv-01341-AWT

Document 88-3

Filed 08/03/2007

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EXHIBIT B

Case 3:02-cv-01341-AWT

Document 88-3

Filed 08/03/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT LEO FELIX CHARLES V. PAULINE HUSBAND : : : : : : : CASE 3:02CV1341(AWT)

AUGUST 3, 2007

THE PLAINTIFF'S PROPOSED VOIR DIRE QUESTIONS

A. Where you previously acquainted with other member of the jury before assembling for this jury panel? B. Have you ever served previously as a member of a trial jury? If so, when and in which court? Was it on a civil or criminal case? Were you allowed to reach a verdict? What was the outcome of the trial? Have you ever served as a foreperson on a jury? Was there anything about your experience on a jury that would make it difficult for you to sit on this jury. C. Do you know the plaintiff Leo Felix Charles? D. Do you know the defendant Pauline Husband? E. Do you know Neil Parille or Matthew Beizer, the lawyers for the defendant, or any person employed by the Attorney General's Office? F. Do you know Johanna G. Zelman or Michael Rose, the lawyers for the plaintiff, or any person employed by their law firm, Rose Kallor, LLP? G. Do you know any of the following persons, who may be witnesses in this case, Oreby Holby or Gregory Gayman? H. This is a case filed by Mr. Charles claiming that he was discriminated against on the basis of his race in connection with his being denied the use of a

Case 3:02-cv-01341-AWT

Document 88-3

Filed 08/03/2007

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bathroom while other White and Hispanic individuals were afforded that same right. Have you ever heard of race discrimination cases before? Have you ever formed an opinion about such cases? If so, what is that opinion? I. Have you ever heard anything about this case before today? If so, how did you hear about it? Did you form any opinion about this case? Do you believe that your ability to serve impartially as a juror in this case has been affected by what you have heard or read about this case? J. Have you, any member of your family, or any close friend ever been incarcerated? K. Do you have an opinion about individuals who have been incarcerated? If so what is that opinion? Do you think that opinion might interfere with your ability to serve as an impartial juror in this case? L. Do you regularly work or socialize with persons of a different race? M. Do you hold any view concerning people of a different race that might interfere with your ability to serve as an impartial juror in a case alleging racial discrimination? N. Have you, a close friend or relative, ever been charged with discriminatory conduct in any court or government agency? If so, when, where, what was the charge, and what was the outcome? O. Are you, or have you recently been, an employee of any person or company that has been charged with discriminatory conduct in any court or government agency? Would anything about that experience affect your ability

Case 3:02-cv-01341-AWT

Document 88-3

Filed 08/03/2007

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to be a fair and impartial juror in a case involving claims of racial discrimination? P. Have you, a close friend or relative, ever had a bad experience of any sort with a person of another race that may affect your ability to be a fair and impartial juror in this case? Q. Do you believe that you have ever been the victim of discrimination on the basis of race or color? If so, please describe the circumstances. Did you file a complaint with any government agency about the discrimination? If so, what was the result? Would anything about that experience affect your ability to be a fair and impartial juror in a case involving claims of racial discrimination? R. Do you believe that blacks and other minorities complain too much about discrimination? S. Do you think that some people use the claim of racial discrimination as an excuse for their shortcomings? T. Do you think that the government has gone too far in protecting the rights of blacks and other minorities? U. Are you opposed to laws requiring affirmative action on behalf of minorities? Do you believe that less qualified minorities get jobs or promotions because of affirmative action? V. What social, civic, fraternal, or political organizations are you a member of? Have you, or a close friend or relative, ever belonged to a social, civic, political, or fraternal organization or club that restricts membership on the basis of race?