Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv-00911-GMS

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Filed 12/21/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE __________________________________________ JAN KOPACZ AND CATHY KOPACZ v. DELAWARE RIVER & BAY AUTHORITY and CRAIG SWETT : : : : : : : : : CIVIL ACTION NO. 04-911

DEFENDANT, DELAWARE RIVER & BAY AUTHORITY'S PROPOSED VOIR DIRE QUESTIONS Defendant, Delaw are River & Bay Authority, by and through its attorneys, Donna Adelsberger & Associates, P.C., respectfully requests that the follow ing questions be asked during the voir dire of the jury: 1. This case involves alleged personal injuries to Jan Kopacz w hich

allegedly occurred on August 9 2002, w hile w orking as a deckhand aboard the ferry, M/V DELAWARE. Is anyone familiar w ith the actual facts of this incident or have any know ledge or communication in any w ay that relates to this incident? 2. Has anyone on the panel ever traveled on the Delaw are River & Bay

Authority ferries w hich operate betw een Lew es, Delaw are and Cape May, New Jersey? 3. Do you know or have any dealings w ith anyone w ho has ever w orked

for the Delaw are River & Bay Authority? 4. Do any of you know or have any dealings w ith the follow ing See w itness list.

individuals w ho may be called as w itnesses in this case:

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5.

Does anyone on the panel know or ever been treated by any of the

follow ing medical providers: See attached list. If so, please describe the nature of your treatment or dealings w ith these medical providers. 6. Have you or anyone close to you ever w orked in the maritime

transportation industry? 7. 8. Have you or anyone close to you ever been injured at w ork? Have you or anyone close to you ever suffered from a neck, shoulder

or back injury or had a bad back? If so, please describe the injury, how it occurred and w hether it has resolved. 9. Is anyone currently suffering from a physical condition that w ould tend

to make you sympathize w ith the Plaintiff? 10. Do any of you take prescription pain medication? If so, state the

reason for taking the medication. 11. Have you or anyone close to you ever been injured in an auto

accident? If so, please describe the accident and resulting injury, if any. 12. Has anyone on the panel ever sustained a serious injury? If so, (1)

w hat w as it; (2) how did it happen, and (3) have you recovered? 13. Have you or anyone close to you ever been involved in a personal

injury law suit, either as a plaintiff or defendant? If so, w hat w as the nature and outcome of the case? 14. Have you sat on a jury panel before? If so, w hat type of case w as it 2

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and w as a verdict reached? 15. Have you or anyone close to you ever been employed in the legal or

medical profession? If so, describe your training and/or occupation and for w hom are you currently employed? 16. Can you disregard any sympathy you may feel for the plaintiff by

rendering a fair and impartial verdict in this case? 17. Do you feel that the Plaintiff is entitled to an aw ard of monetary

damages in this case just because he filed a law suit? 18. Do you agree that a business is to be treated the same as an

individual in rendering your decision in this case? 19. Is there any other reason that has not been covered w hich you believe

w ould prevent you from making a fair and impartial decision in this case? If so, w hat is your reason? Defendant reserves the right to privately question individual panel members during the voir dire, if appropriate, and to supplement these questions w ith proper notice. Respectfully submitted, DONNA ADELSBERGER & ASSOCIATES, P.C.

BY:s/ Mary Elisa Reeves, Esquire Mary Elisa Reeves, Esquire Donna L. Adelsberger, Esquire Attorneys for Defendant Delaw are River and Bay Authority Date: December 21, 2005 3