Free Proposed Voir Dire - District Court of Connecticut - Connecticut


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Date: December 31, 1969
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Category: District Court of Connecticut
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Case 3:00-cv-00973-AHN Document 106 Filed 02/16/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
C.A. NO.: 3:00 CV 0973 (AHN) (HBP)
TIMOTHY HAYES, )
)
Plaintiff, )
)
v. )
)
COMPASS GROUP USA, INC., )
d/b/a EUREST DINING SERVICES )
and CARY ORLANDI, )
)
Defendants. )

DEFENDANTS' PROPOSED VOIR DIRE QUESTION S
Pursuant to Fed. R. Civ. P. 47(a) and Section 10 of this Court’s Pre-Trial Order,
defendants Compass Group USA, Inc. ("Compass") and Cary Orlandi ("Orlandi") request that
the Court ask the following voir dire questions of potential jurors:
l. Does any prospective juror, or his or her family member, know Timothy Hayes,
anyone in his family, or any of the witnesses i_n this case?
2. Does any prospective juror, or his or her family member, know Cary Orlandi,
anyone in his family, or any of the witnesses in this case?
3. Does any prospective juror or family member of a juror work for (or has he or she
ever worked for) Compass Group, USA or any of its affiliates or subsidiaries?
4. Has any prospective juror or family member of a juror ever been involved in
litigation of any kind involving any of the parties?
5. Has any prospective juror, a member of his or her family, ever claimed to be the
victim age discrimination by an employer?
{00052871.DOC/2}

Case 3:00-cv-00973-AHN Document 106 Filed 02/16/2005 Page 2 of 3
6. Has any prospective juror or family member ever been involved in any lawsuit, as
a party or witness, involving allegations of discrimination?
7. Has any prospective juror (or any family member) ever felt that he or she has
been unfairly terminated or demoted from a job position?
8. Has any prospective juror ever felt that an employer made an employment
decision about him or her, or any family member, based on age?
9. Is any prospective juror a past or present member of a union?
WHEREFORE, Defendants request that any juror answering any of the foregoing
questions affirmatively be questioned as to the particulars of his or her answer outside the
presence of the remaining jurors.
COMPASS GROUP, USA, INC. and
CARY ORLANDI,
By their attorneys,
Christopher A. Kermey, Fed. Bar # CT25017
Margaret H. Paget, Fed. Bar # CT25016
Sherin and Lodgen LLP
101 Federal Street
Boston, MA 02110
(617) 646-2000
’J\
o*\ k . A
La rence Peikes ( Clfqqq fg)
Wiggin & Dana LLP
400 Atlantic Street
P.O. Box 110325
Stamford, CT 06911-03251
Dated: February 16, 2005
{00052871.DOC/2}
2

Case 3:00-cv-00973-AHN Document 106 Filed 02/16/2005 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a true copy of the foregoing Defendants’ Proposed Voir Dire
Questions was served on this 16th day of February, 2005, by Federal Express overnight delivery
on:
Stephen F. McEleney, Esq.
McEleney & McGrail
363 Main Street
Hartford, CT 06106
2 L`.- l L3
Lawrence Peikes