Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:03-cr-00003-EBB

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : CRIMINAL ACTION NO. : 3:03CR3(EBB) : : : FEBRUARY 28, 2005 : : :

UNITED STATES vs. ANTHONY D. AUTORINO Defendant.

DEFENDANT'S PROPOSED VOIR DIRE QUESTIONS

The defendant, Anthony D. Autorino, respectfully requests that the following supplemental voir dire questions be submitted to the jury in addition to the questions typically posed by the Court. I 1. Parties & Case Have you heard, read or seen anything about this case? (a) 2. 3. If yes, please explain.

Have you heard of, or done business with, the defendant in this case, Anthony D. Autorino? The following is a list of the attorneys representing the government, the defendants, or witnesses in the case. Do you know, or have you heard of, or have you worked with any of the following attorneys? Stanley A. Twardy, Jr.

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John B. Nolan Edgardo Ramos Michael G. Considine Cecily Kerr Ziegler Day, Berry & Howard LLP AUSA James G. Genco AUSA Thomas V. Daily (a) 4. If yes, please identify which person and in what context you know that person.

The following is a list of names of people you may hear from or about during this trial. Do you know, or have you heard of, or have you worked with any of the following individuals: Ely Bennett Roger Bernhammer Terry Dorman Kenneth Dorros F. Owen Eagan Michael Fawcett Patricia Huff Durwin Jones John Koslow Susan Krauss Peter McDonald Gordon Muir Charles Pryce Jennifer Riber Chuck Singleton Frank Williams Brad Wolfe (a) If yes, please identify which person and in what context you know that person

5.

Have you ever had any experience with, or do you have any connection with, any of the following entities? ADS Realty Central Bank

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Fairchild Industries Federal Deposit Insurance Corporation ("FDIC") Intermedia Communications, Inc. New Bank of New England Republic Credit Corporation Sentinel Bank Shared Technologies, Inc. Shared Technologies Fairchild, Inc. (a) II. 6. If yes, please explain.

Background/Employment Where do you work (if unemployed or retired, where did you last work)? (a) (b) How long have you worked there? What other jobs have you held?

7. 8.

How far did you go in school? Are you single, married, divorced, widowed? (a) If married, or otherwise living with someone, what does your spouse/partner do?

9.

Have you ever served in the military? (a) If yes, what branch, what rank, and for how long?

10.

Have you, any relative, or anyone close to you ever worked in the legal profession in any capacity, including but not limited to, as a prosecuting attorney, criminal defense attorney, judge, legal secretary, or paralegal? (a) (b) If yes, please provide that person's name, relationship to you, and the area of law in which he or she worked. Have you had any direct personal experiences with any person working in the legal profession in any capacity, including, but not limited to, as a prosecuting attorney, criminal defense attorney, judge, legal secretary, or paralegal?

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II. 11.

Experience with Crime and/or Fraud Have you, any relative, or anyone close to you ever been a victim of a crime or a complaining witness in a criminal case? (a) If yes, please explain.

12.

Have you, any relative, or anyone close to you ever been charged with, convicted of, or investigated concerning a criminal offense, other than minor traffic violations? (a) If yes, please explain.

13.

Have you, any relative, or anyone close to you ever been the victim of a fraud, or the victim of a scam or con artist? (a) If yes, please explain.

14.

Do you know anyone who has been accused or convicted of fraud or making false statements? (a) If yes, please explain.

15.

Many corporations and their financial problems have been reported about in the news. Do you have strong feelings concerning these corporations, the people who work there, and any financial problems they may have had? Do you think that you, any relative, or anyone close to you, have been negatively impacted by any corporate financial problems or fraud? Financial and/or Business Experience Have you taken any courses or had any training in business, finance, investment, or any similar area? (a) If yes, please explain how many courses and/or how much training you have had and identify the areas in which you have had courses/or training.

16. IV. 17.

18.

Have you ever invested in the stock market?

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(a) 19.

If yes, have you either (a) ever sustained a significant loss, and/or (b) stopped investing in the stock market in the last five years? Please explain.

Have you ever felt taken advantage of in a business dealing? (a) If yes, please explain.

20.

Have you ever been owed a debt that was not paid? (a) If yes, please explain:

21.

Have you ever defaulted on a loan? (a) If yes, please explain:

III. 22.

Experience with Government and/or Related Agencies Have you, any relative, or anyone close to you, ever been employed by any federal, state or local law enforcement agency, any other federal, state of local governmental agency, or any private detective agency or security firm? (a) If yes, please explain.

23.

Have you, any relative, or anyone close to you had any experience involving law enforcement officials or government agents that might prevent you from considering the evidence in this case fairly and impartially? (a) If yes, please explain.

24.

Would you give greater or lesser weight to the testimony of a law enforcement officer or government agent than to the testimony of any other witness simply because the witness was a law enforcement officer or government agent? (a) If yes, please explain.

VI. 25.

Previous Jury or Trial Experience Have you ever served on a State or Federal Grand Jury?

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(a) 26.

If yes, please explain.

Have you ever served as a juror in a criminal case? (a) If yes, please explain the case and what the verdict was.

27.

Have you ever served as a juror in a civil case? (a) If yes, please explain the case and what the verdict was.

28.

Have you, any relative, or anyone close to you ever been a plaintiff (i.e., files a lawsuit) or been a defendant (i.e., been sued) in a civil case? (a) If yes, please explain.

V. 29.

Justice System The Court will instruct you that, as a matter of law, a defendant is presumed to be innocent on each of the charges against him and the burden is entirely on the government to prove his guilt on that charge beyond a reasonable doubt. A defendant does not have to prove that he is not guilty. Would it be difficult to follow these instructions? (a) If yes, please explain.

30.

The Court will instruct you that you must wait until all of the evidence has been presented and the Court has instructed you on all of the applicable law before you can reach a conclusion with respect to any of the charges against the defendant. Would it be difficult for you to follow this instruction? (a) If yes, please explain.

31.

Some people have religious or philosophical views that prevent them from acting as jurors and in effect judging other people. Do you have any such beliefs that would affect your ability to serve as a juror? (a) If yes, please explain.

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DEFENDANT, ANTHONY D. AUTORINO

By

_____________________________ Stanley A. Twardy, Jr. (ct05096) John B. Nolan (ct05583) Edgardo Ramos (ct23984) Day, Berry & Howard LLP One Canterbury Green Stamford, CT 06901 (203) 977-7300 His Attorneys

CERTIFICATION

THIS IS TO CERTIFY that a copy of the foregoing was sent via facsimile and regular mail, on this date, to the following individuals: Thomas V. Daily, Esq. James G. Genco, Esq. Assistant United States Attorneys Office of the United States Attorney 157 Church Street, 23rd Floor New Haven, CT 06510

___________________________________ Stanley A. Twardy, Jr.

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