Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:02-cv-00618-MRK

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------------------------------X GEORGE FOSTER-BEY Plaintiff, v. JOHN E. POTTER, POSTMASTER GENERAL, UNITED STATES POSTAL SERVICE, Defendant ---------------------------------------------------------X Civil No. 3:02CV00618 (MRK)

February 9, 2004

DEFENDANT'S REQUESTED VOIR DIRE EXAMINATION OF THE JURY The Defendant, Postmaster General, United States Postal Service, respectfully requests that the following questions be asked of the prospective jurors, in addition to those generally asked by the Court. 1. The United States Postal Service is represented in this case by Anna V.

Crawford of the United States Postal Service and Douglas Morabito of the United States Attorney's Office. Do any of you know Mr. Morabito or Ms. Crawford? 2. Do any of you know, or are any of you related in any way to anyone

associated with the United States Attorney's Office or the United States Postal Service? 3. The Plaintiff in this case is George Foster-Bey. Do any of you know or are

any of you related in any way to Mr. Foster-Bey? If so, whom do you know and what is the relationship? 4. The witnesses in this case are: [list].

Do you know or are any of you related to any of them? 5. The Plaintiff is represented by Martyn Philpot and Marc Glenn. Do any of

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you know Mr. Philpot or Mr. Glenn? If so, how are you acquainted with them and what is the relationship? 6. Have any of you retained the services of any of the lawyers mentioned

thus far? If so, when and what was the nature of the legal problem? 7. This case involves whether the United States Postal Service treated the

Plaintiff properly in the context of the governing federal statute, (Title VII) The Civil Rights Act of 1964, 42 U.S.C. § 2000e. The issues you will have to decide concern whether the Plaintiff was discriminated against because of his race. 8. In this trial the Plaintiff alleges that he was discriminated against by the

Defendant Postal Service when, after some of his employees reported that he turned on a mail sorting machine while a mechanic was working on it, the Postal Service placed him on leave, the incident was investigated, and when he returned to work, he was treated differently by Postal management. 9. Have you read, seen, or heard anything about this case, or do you have

any knowledge, opinions, or concerns about any part of this case, which might influence or affect your consideration? 10. Have any of you had an experience in your employment, or with the

United States Postal Service, or the United States Government, which would cause you any difficulty in fairly evaluating the testimony from their employees one way or the other, or the evidence in general in regards to these matters? 11. Have any of you ever filed a complaint or claim against your employer?

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12.

Is there anyone who feels that sympathy or compassion for a person with

Plaintiff's experience might interfere with his or her ability to render a verdict based on the facts as they are presented, and the law as I will charge it to you? 13. Have you ever participated in a trial before in any capacity? For example,

have any of you ever been a party to a lawsuit, or a witness, or a juror? If so, when, in what court, and in what way did you participate? 14. Do you all understand that it will be your obligation as jurors on this case

to decide the case based on the evidence presented to you in this courtroom without prejudice or sympathy, the law as I give it to you, and nothing else? Do any of you have any reason to believe that you would not be able to decide this case solely upon the evidence presented and the law as I give it to you?

Respectfully submitted, KEVIN O'CONNOR UNITED STATES ATTORNEY,

BY:

_______________________________ Anna V. Crawford Special Assistant U.S. Attorney United States Postal Service Northeast Area Law Office, USPS 8 Griffin Road North Windsor, CT 06006-0170 Federal Bar No. ct01394 Tel. (860) 285-7309

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