Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:00-cv-OO656§RU Document 89 Filed O3/@004 Page 1 of 3
UNITED STATES DISTRICT COURT E D I
DISTRICT OF CONNECTICUT F I L _
‘ZIIiIII MAR 30 A II= 3I
MARSHALL CHAMBERS, }
. . U. _
V Plaintiff I Docket No.B§!§Q§;%®%%H§I:2U)
}
Defendant-ANTHONY J. PRINCIPI } I
Secretary, U.S. Department of } I
Veterans Affairs, } March 28, 2004 ‘
Defendant . }
PLAINTIFFS PROPOSED IURY QUESTION S
1. Have you or any members of your family ever worked for the Department I
of Veterans’ Affairs? If so, in what capacity? I
2. Have you, a family member, or a close friend, ever been denied promotion
by any employer?
3. If so, what action(s) did you, the family member, or friend, take because of I
the denial of promotion? Have you ever opposed or grieved the denial of I
a promotion?
4. Conversely, have you, a family member, or a close friend, ever denied
promotion, or supported the denial of promotion, to any employee under
your supervision? If so, under what circumstances?
5. What were the specific reasons for the refusal to promote the particular
employee?
6. What action(s) did that employee take in response to the decision not to
promote him or her?
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__ Case 3:00-cv-OO6?6>§FtU Document 89 Filed O3/%O?OO4 Page 2 of 3 I
7. Have you ever been plaintiff, defendant, or a witness, in any lawsuit,
administrative, or other proceedings, involving allegations of N
discrimination?
8. Would you prefer a female secretary over a male secretary?
9. Traditionally women have dominated in the secretarial field, do you have A
any preconceived notions that the secretarial field should remain
dominated by women?
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10. Have you, a family member or friend, ever applied for a promotion, and
that promotion, was given to a minority person?
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11. Conversely, has any minority person under your supervision, ever i
applied for a promotion and that promotion was given to a non—minority
person?
12. Do you believe that blacks have an advantage in the work place in terms
of getting promoted over whites? y
13. Would the fact that this case involves claims by an individual against the
Department of Veterans’ Affairs influence you in any way?
14. Do you believe that black veterans are treated the same as others?
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15. Would the fact that this case involves discrimination claims against the
Department of Veterans’ Affairs influence you in any way?
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__ Case 3:00-cv-OOGQGSJSRU Document 89 Filed O3/@@004 Page 3 of 3
16. Where there is an agreement between employer and an employee, or his
union, should the employer honor that agreement?
Respectfully submitted,
F I F, MA HAMBERs
c.‘S2/¢»(*>·v· #.7 '»·.°»c.C al
CA . ILGRI , ESQ.
LAW OFFICES OF CALEB M.
PILGRIM, LLC
1404 WHALLEY AVENUE, 2ND FLOOR
NEW HAVEN, CT 06515
(203) 387-2524
FEDERAL BAR NO. CT14857
CERTIFICATE
I hereby certify that a copy of the foregoing s mailed to Attorne Lauren
Nash, AUSA, U.S. Department of Iustice, 7 hurch Stre aven, CT
06510 M h 28, 2004. . _
On arc .¢2./(/¢$»7v¤ Q/$@1 vw
CALEB M. PILGRIM, ESQ.
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