Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:03-cv-01034-AVC

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Filed 02/11/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : CIVIL ACTION NO.: 303CV01034(AVC) : : : : : FEBRUARY 11, 2005

DARLA PATTON FKA DARLA DOLGINOFF VS. JAMES CUSANO

PROPOSED VOIR DIRE QUESTIONS OF DEFENDANT, JAMES CUSANO

GENERAL BACKGROUND: Have you been a juror before? What kind of case? Did it go conclusion? Would that experience adversely affect your ability to be a fair and impartial in this case? Do you make up your mind quickly, slowly or somewhere in between? Would you be able to keep an open mind as to this case and reach and not reach a conclusion until you hear all of the evidence? Do you have any strong feelings about the civil justice system? Do believe that the plaintiff should be awarded damages just because she brought a lawsuit? Do you believe the defendant must have done something wrong just because he was sued?

Case 3:03-cv-01034-AVC

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LAWSUIT EXPERIENCE Have you or members of your family ever been involved in an incident where someone was hurt, and either you sued someone or someone sued you? When did this happen? Is the case still pending? Did it go to trial or was it settled? Where you satisfied with the outcome? Was there anything about that experience that left you with any strong feelings about the civil justice system? Is there anything about your experience that would adversely affect your ability to be a fair and impartial juror in this case? Have you ever been to Las Vegas? Is there anything about your experience in Las Vegas that would adversely affect your ability to be fair and impartial in this matter? Have you ever been to the Tropicana Hotel and Casino in Las Vegas? Is there anything about your experience at Tropicana Hotel and Casino in Las Vegas?

INCIDENT EXPERIENCE:

Have you ever been involved in an incident that resulted in personal injury? When did it occur? Where did it happen?

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What kind of injuries were sustained? Were any permanent injuries sustained? Where there any mental injuries sustained? Is there anything about the experience that would adversely affect ability to be a fair and impartial in this case? MEDICAL KNOWLEDGE During the course of this trial, you may hear testimony from psychologists or psychiatrists. What is your opinion about the ability of psychologists or psychiatrists to identify and explain the reason for human behavior? Have you or any members of your immediate family ever worked for a psychologist, psychiatrist, therapist, mental health counselor, at a mental health clinic or psychiatric hospital or similar setting? Have you ever received any training or engaged in the study of psychology or psychiatry? Have you or any member of your immediate family ever been treated for Post Traumatic Stress Disorder?

EXPERT WITNESSES:

Expert witnesses are allowed to give opinions. Will you make sure that any opinion offered to you makes common sense to you? Will you make sure that any opinion offered to you fits in with the rest of the evidence?

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APPLYING THE LAW: The judge may instruct you on an area of the law that you personally disagree with. If confronted with that situation, would you be able to set aside your feelings and apply the law as the judge gives it to you?

The judge may instruct you that your decision in this case is not to be the result of sympathy. Can you set sympathy aside so that it does not play a part in your decision?

THE DEFENDANT, James Cusano

BY:____________________________ Michael L. McDonnell, Esq. 700 Stanley Drive, P.O. Box 9011 New Britain, CT 06050-9948 Telephone: (860) 827-4351 Facsimile: (860) 827-4386 Federal Bar No.: CT 04108

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CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing was mailed, postage prepaid, on February 11, 2005, to:

Joseph M. Porto, Esq. Parrett Porto Parese & Colwell, P.C. 2319 Whitney Avenue Hamden, CT 06518

_______________________________ Michael L. McDonnell, Esq. 700 Stanley Drive, P.O. Box 9011 New Britain, CT 06050-9948 Telephone: (860) 827-4351 Facsimile: (860) 827-4386 Federal Bar No.: CT 04108

Law Offices, Rodd J. Mantell, Managing Attorney 700 Stanley Drive, New Britain, CT 06050-9011 ­ (860) 827-4351 Juris #411076