Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:03-cv-00636-JBA

Document 74

Filed 02/24/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EVELINE GOINS v. JBC & ASSOCIATES, P.C. ET AL. CASE NO. 3:03CV 636 (JBA) February 23, 2005

PLAINTIFF' PROPOSED VOIR DIRE S Pursuant to the Court'Order, plaintiff submits the attached voir dire. Defense s counsel was provided with the proposal and declined to comment. Defense counsel advises that his clients, including Brandon and Boyajian, officers of the court (attorneys) in New Jersey and California respectively, have not responded to his communications about this Court'Trial and Settlement Conference orders. s

THE PLAINTIFF

BY____/s/ Joanne S. Faulkner___ JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 06511-2422 (203) 772-0395 [email protected]

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Case 3:03-cv-00636-JBA

Document 74

Filed 02/24/2005

Page 2 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EVELINE GOINS v. JBC & ASSOCIATES, P.C. ET AL. CASE NO. 3:03CV 636 (JBA) February 23, 2005

PLAINTIFF' PROPOSED VOIR DIRE QUESTIONS S (In addition to standard questions as to whether they know the parties/ attorneys/ witnesses/ have prior jury experience or have ever been party to a lawsuit) 1. Are you or have you been in a business that tries to collect past due or unpaid accounts? 2. Do you have any family or household members or close friends who are or have been in a business that tries to collect past due or unpaid accounts? 3. Have you or has anyone in your family or friends worked for JBC & Associates, P.C., JBC & Associates, Inc., JBC Legal Group, P.C. or Boyajian Law Offices, P.C.? 4. If you find that JBC, Mr. Boyajian, or Mr. Brandon has violated any law, is there any reason you would NOT be willing to award damages to Ms. Goins for her emotional distress in accordance with the instructions given to you by the Court? 5. If you find that that JBC, Mr. Boyajian, or Mr. Brandon has violated any law, is there any reason you would NOT be willing to award statutory damages even if Ms. Goins had no actual damages for emotional distress and the like? 6. If you determine that that JBC, Mr. Boyajian, or Mr. Brandon has willfully violated any law, would you, for any reason, NOT be willing to award punitive damages to Ms. Goins in accordance with the instructions given to you by the Court? 7. Is there any reason that you could not sit and hear this case and render a verdict, in accordance with instructions given by the Court, which would be fair to both the plaintiff and the defendants under the evidence as it may be presented?

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Case 3:03-cv-00636-JBA

Document 74

Filed 02/24/2005

Page 3 of 3

8. Do you have any philosophical, religious, or other belief that would prevent you from sitting in judgment on a case? 9. Do you have any health problems, such as hearing or eyesight, or any need to take medication which would interfere with your ability to sit as a juror on this case? 10. Could you not be fair and impartial, for any reason, whether for some reason that has already been discussed or any reason that has not been discussed, such as your beliefs or convictions about individuals, corporations, or the jury system?

This is to certify that the foregoing was emailed on February 23, 2005, postage prepaid, to: Jonathan D. Elliot Sabatino Fiano P. O. Box 763 Southport CT 06490

___/s/ Joanne S. Faulkner___ Joanne S. Faulkner

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