Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:00-cv-00681-RNC

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

NORMA WATTS, In her Individual Capacity and as Administratrix of the Estate of AQUAN SALMON V. CITY OF HARTFORD; POLICE DEPARTMENT OF THE CITY OF HARTFORD; JOSEPH F. CROUGHWELL, Individually and in his Official Capacity as Chief of Police of the City of Hartford; OFFICER ROBERT C. ALLAN, Individually and in his Official Capacity as a Hartford Police Officer

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CIVIL ACTION NO. 3:00CV0681 (DJS)

JUNE 7, 2004

DEFENDANTS' PROPOSED VOIR DIRE QUESTIONS The undersigned defendants request that each of the prospective jurors be required to identify themselves, giving their number, name, their address for the past five years, their occupation for the past five years and occupation of their spouses for the past five years. The defendants request that they then be asked the following questions: 1. Have any of you ever served as a juror previously, either in State or

Federal Court? If so, where and when was it and did it involve civil or criminal cases.

05645.0555

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2.

Are you or any members of your family or friends related to any of the

attorneys representing any of the parties to this action? If so, what is the relationship? 3. Have you or any members of your family or friends ever been represented

by, or are you or they socially acquainted with, any of the attorneys who represent any of the parties to this action? If so, state when and where the representation of such attorney, or the extent of the acquaintance with such, occurred. 4. Do you or any members of your family or friends know the plaintiff or any

members of her family? 5. Do you have any knowledge about this lawsuit or any other lawsuit

involving the action of any law enforcement agency? 6. Do you or any members of your family or friends know any of the people

who are expected to be witnesses in this case or any of the organizations with which the witnesses are associated? 7. Do you have any underlying bias or prejudice where local or state police

officers are concerned, and if so, what are those biases or prejudices? 8. Do you have any particular feelings concerning the defendant which would

in any way affect your ability to be fair and impartial in this case? 9. Have you or any members or your family or friends ever worked for any

police department or law enforcement agency?

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10. 11.

Have you or any members of your family or friends ever studied law? Have you or any members of your family or friends ever made a claim or

brought a lawsuit concerning the actions of any police department or employee of any police department or agency? If so, what was the basis of that claim? 12. Have you ever been a party to a lawsuit or brought a claim for money

damages, if so: (a) (b) (c) 13. lawyer? 14. Is there any one of you who, if instructed to do so by the Judge, could not did you bring the suit or claim or was it brought against you; what was the nature of the lawsuit or claim; how was the suit or claim resolved.

Have you or any members of your family or friends ever worked for a

or would not be able to put aside all natural feelings of sympathy during jury deliberations and decide this case strictly on the facts and the law? 15. Do any of you feel that because this case involves the actions of police

personnel that you would not be able to put aside all natural feelings either pro or con with respect to police officers, and decide this case strictly on the facts and the law. 16. If there are any one of you who would find it extremely difficult, if not

impossible, to follow the Judge's instructions not to discuss the case outside of the

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courtroom with anyone, including family members, and not to read about the case or listen to any possible broadcasts about it on the radio or television? 17. Are there any among you who feel that merely because a person brings a

lawsuit and claims money damages that such person is entitled to be awarded damages by a jury without first proving that the defendant is liable under the law? 18. Are there any among you who feel that merely because the defendant has

been sued that he must have done something wrong or must legally be at fault? 19. Are there any among you who feel that even if the plaintiff fails to prove

her case against the defendant, you could not or would not send the plaintiff home without any money because she claims she has suffered a great deal and incurred expenses? 20. Do any one of you feel now, before hearing any of the evidence, that you

are inclined to lean towards any party or be sympathetic towards the position of any party? 21. Do any of you know anything about the circumstances surrounding this

lawsuit, through information in the media or otherwise? 22. Have any or you or any members of your family worked for the City of

Hartford, or any other municipality? If so, in what capacity.

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23.

Have you or any members of your family ever had any negative

experiences, including but not limited to, being arrested, with any police officer or any member of a law enforcement agency? If so, what was the nature of the negative experience? 24. Do any of you have any opinion about the quality of police service

provided by the City of Hartford? If so, what is that opinion. 25. Have any of you read any publications in the media regarding any of the

parties to this lawsuit and if so, whether any information you obtained from those publications would affect your ability to be fair and impartial in this case? 26. 27. Do you have any strong feelings about the use of firearms? Are you a member of the American Civil Liberties Union or any

organization devoted to the protection of civil rights or civil liberties?

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THE DEFENDANTS: CITY OF HARTFORD, JOSEPH CROUGHWELL AND ROBERT C. ALLAN

By James J. Szerejko of HALLORAN & SAGE LLP Fed. Bar #04326 One Goodwin Square 225 Asylum Street Hartford, CT 06103 (860) 522-6103 CERTIFICATION This is to certify that on this 7th day of June, 2004, I hereby mailed or handdelivered a copy of the foregoing to: Joseph A. Moniz, Esq. 100 Allyn Street Hartford, CT 06103 Nicholas P. Cardwell, Esq. Cardwell, Cardwell & Smoragiewicz 108 Oak Street Hartford, CT 06106

James Szerejko

544677.1(HS-FP)

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