Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:02-cv-01341-AWT

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EXHIBIT A

Case 3:02-cv-01341-AWT

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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 DEFENDANT'S PROPOSED VOIR DIRE QUESTIONS

1.

This is a case brought by an inmate confined to the custody of the

Commissioner of Correction alleging that the defendant, a nurse employed by the Connecticut Department of Correction, discriminated against him when he made a request to use the bathroom in the Medical Department. Having heard this brief summary, is there any reason why you might have difficulty deciding this case in a fair and unbiased manner if you were chosen to serve on this jury? If so, please explain. 2. Have you, any member of your family or close friends ever been involved

in what you consider to be a negative or unpleasant experience with a physician, nurse or other member of the medical profession? If so, do you feel that this experience would make it difficult for you to be fair and impartial in deciding this case? 3. Have you, any member of your family or close friends ever filed a

complaint against a physician, nurse or other medical practitioner? If so, please describe the circumstances surrounding the complaint and the outcome thereof. 4. Have you or any member of your family or close friends ever been

involved in a situation where you felt that you or your family member or friend was discriminated against due to your race, religion or any other reason. If so, do you feel

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that this exposure would make it difficult for you to be fair or impartial in deciding this case. 5. Does anyone here have any feelings or beliefs that a nurse employed by

the Connecticut Department of Correction would be any less competent or less diligent than other nurse simply because he or she works for the Department of Correction? 6. Have you, or anyone close to you, ever been arrested? Spent time in jail?

Visited someone in jail? Worked in a jail? If so, do you feel that this experience would influence your ability to be neutral and fair in deciding this case? In what way? 7. Have you, any member of your family or close friends ever been a party to

a lawsuit? If so, please state whether you were a plaintiff or defendant, whether it was an unpleasant experience or not, whether you have any negative feelings about the justice system as a result of your experience? 8. Have you ever served on a jury before? If so, please identify the location

and nature of the case or cases on which you served. 9. Have you, or has any member of your family, ever been involved in what

you consider to be a negative or unpleasant experience with the Department of Correction or any employee of the Department of Correction? If so, explain. 10. Have any of you heard or read anything about the Department of

Correction or its employees which would in any way interfere with your ability to be objective and impartial in this case? 11. Have you or has any member of your family ever been sued by the State

of Connecticut or any other governmental agency, or filed a lawsuit against the State of

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Connecticut or any other governmental agency? If so, do you feel that this experience would influence your ability to be neutral and fair in deciding this case? 12. Does anyone believe that monetary damages should be awarded to the

plaintiff just because he has filed a lawsuit or just because he allegedly has been injured? 13. In considering this case, if the evidence so warranted, would you have any

difficulty in rendering a verdict for the defendant and against the plaintiff, despite any feelings of sympathy you may have for him? 14. Do you have any physical or medical problems that would make it

difficult for you to sit as a juror? 15. Is there anything in your education, background or experience or

otherwise that leaves you with any preconceived notion, bias, prejudice in a case such as this that would keep you from being a fair and impartial juror if you are selected?

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