Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:02-cv-02101-AVC

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CYNTHIA WELFARE, : : Plaintiff, : : vs. : : PETER O'MEARA THE COMMISSIONER OF : THE DEPARTMENT OF MENTAL : RETARDATION FOR THE STATE OF : CONNECTICUT, : : Defendant. : _______________________________________: CIVIL ACTION NO. 3:02CV2101(AVC)

MARCH 11, 2005

PLAINTIFF'S PROPOSED VOIR DIRE QUESTIONS 1. Do you know any of the lawyers or law firms involved in this case, or have

you or any close friend or relative ever been a client of either of the law firms? a. If so, please explain the nature of the relationship and state whether you have any feelings that would make it difficult for you to fairly and objectively render a verdict for or against that lawyer' s client.

2.

Do you know the Plaintiff in this case, Cynthia Welfare? a. If so, please explain how you know her and state whether you have any feelings that would make it difficult for you to fairly and objectively render a verdict for or against Ms. Welfare.

3.

Do you know the individual Defendant in this case, Peter O'Meara? a. If so, please explain how you know him and state whether you have any feelings that would make it difficult for you to fairly and objectively render a verdict for or against the Plaintiff Ms. Welfare.

4.

Defendant O'Meara is the Commissioner of the Connecticut Department

of Mental Retardation. Have you or any close friends or relatives ever been 1

Case 3:02-cv-02101-AVC

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employed by the Department of Mental Retardation or by the State of Connecticut? a. If so, please state who was employed, describe the position held, and state when.

5.

Have you or any close friends or relatives who received services from the

Department of Mental Retardation? a. 6. If so, please state who received services and state when.

Do you have any opinions about the Department of Mental Retardation? a. If so, please explain those opinions and state whether those opinions would make it difficult for you to fairly and objectively render a verdict for or against Ms. Welfare.

7.

Have you or any close friends or relatives ever been involved in a dispute

of any nature with a federal, state, or local government agency? a. If so, please state the nature of the dispute.

8.

Do you know any of the following individuals who may be called as

witnesses or whose name may come up on this case: Cynthia Welfare Irene Curtin Kate Groves Nancy Block Gayle Krantz Betsy Mossberg Laurie Deane

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Dawn Closs-Harris Peter O'Meara a. If so, please explain the relationship and state whether you have any feelings that would make it difficult for you to fairly and objectively evaluate any testimony given by that person.

9.

Have you, a relative, significant other, or close friend ever been accused

of misconduct by a government agency? a. If so, please explain the circumstances.

10.

Have you or any close friend or relative ever been employed in the

personnel, human resources, or labor relations field for a corporation or a government agency? a. If so, please state when you or the close friend or relative held the position and describe the nature and duties of the position.

11. Have you or any close friend or relative ever been in a supervisory position? a. If so, please state when you or the close friend or relative held the position and describe the nature and duties of that position.

12.

Have you or a close friend or relative ever terminated an employee who worked for you? a. If so, please state the circumstances under which the employee was terminated and the reasons for the termination.

13. Have you or any close friend or relative ever worked in the human services field? a. If so, please state when you or the close friend or relative held the position and describe the nature and duties of the position.

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14.

Have you or any close friend or relative ever been accused of

discrimination or retaliation with respect to their employment? a. If so, please describe the circumstances of such accusation.

15.

Do you have any opinion about employees who bring lawsuits against

their employers? a. If so, please describe those opinions.

16.

Have you or any close friend or relative ever been involved in a lawsuit as

a party, a witness or a juror? a. b. c. If you were a party, were you a Plaintiff or a Defendant? What type of case? What was the result? If you were a witness, what type of case? For which side did you testify? What was the result? If you were a juror, did the case go to a verdict? What type of case? What was the verdict?

17.

Would you have any difficulty awarding the Plaintiff damages for

emotional distress if you were satisfied that she was entitled to them?

18.

If you are currently employed, please state the position held, the name

and location of the employer, and the length of your employment.

19.

If you are not currently employed, please state the last position you held,

the name and location of the employer, and the length of your employment.

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20.

If you have a spouse or partner who is currently employed, please state

the position held, the name and location of the employer, and the length of his or her employment.

21.

If you have a spouse or partner who is not currently employed, please

state the last position he or she held, the name and location of the employer, and the length of his or her employment.

22.

If you have a child or children who are currently employed, please state

his, her or their position held, the name and location of the employer, and the length of employment.

23.

If you have a child or children who are not currently employed, please

state his, her or their position held, the name and location of the employer, and the length of employment.

RESPECTFULLY SUBMITTED, THE PLAINTIFF, By: ______________________________ Peter Goselin ct16074 Livingston, Adler, Pulda, Meiklejohn & Kelly, P.C. 557 Prospect Avenue Hartford, CT 06105-2922 Ph: (860) 233-9821 Fax: 860-232-7818 Email: [email protected]

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