Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:04-cv-01394-GMS

Document 239-2

Filed 06/02/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CAPTAIN BARBARA L. CONLEY, Plaintiff, v. L. AARON CHAFFINCH, Defendant. : : : : : : : : : :

C.A.No.04-1394-GMS

DEFENSE REQUEST FOR ADDITIONAL JURY VOIR DIRE The defendants respectfully request that the Court propound the following questions, directed to the issue of prejudicial pretrial publicity and improper extrajudicial statements by counsel, to the jury pool in the above matter. 1. officers? 2. 3. 4. 5. 6. Has anyone discussed with you, or attempted to discuss with you, this case or Are you aware of the outcome or status of other lawsuits involving the defendant In the past week, have you become aware of any information concerning this case Do you recognize the names of the lawyers for the plaintiffs in this case: Thomas Are you aware of any statements made by the lawyers for the plaintiffs in this other lawsuits involving the defendant or the Delaware State Police or State Police officers? or the Delaware State Police or State Police officers? or other lawsuits involving the defendant or the Delaware State Police or State Police officers? Neuberger and Stephen Neuberger? case: Thomas Neuberger and Stephen Neuberger, regarding this case, former Colonel Chaffinch, the Delaware State Police, or State Police officers? Have you been exposed to any newspaper, radio, or television accounts of this case or other lawsuits involving the defendant or the Delaware State Police or State Police

Case 1:04-cv-01394-GMS

Document 239-2

Filed 06/02/2006

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7.

Are you aware of any statements made by the lawyers for the plaintiffs in this

case: Thomas Neuberger and Stephen Neuberger, regarding other litigation involving either the Delaware State Police, or State Police officers? 8.

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Case 1:04-cv-01394-GMS

Document 239-2

Filed 06/02/2006

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/s/ Ralph K. Durstein, III Ralph K. Durstein, III (ID# 912) Stephani J. Ballard (ID#3481) Deputy Attorneys General Department of Justice State of Delaware 820 N. French Street Wilmington, DE 19801 (302)577-8510 /s/ James E. Ligouri JAMES E. LIGOURI 46 The Green Dover, DE 19901 (302) 678-9900 Attorney for L. Aaron Chaffinch DATED: April 12, 2006

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Case 1:04-cv-01394-GMS

Document 239-2

Filed 06/02/2006

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