Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:03-cv-01034-AVC Document 30 Filed 02/1 1/2005 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
Darla Patton ika Darla Dolginoff : Civil Action No.: 303CV01034
: (AVC)
vs. :
James Cusano February 10, 2005
PROPOSED VIOR DIRE QUESTIONS
In addition to the court’s own voir dire questions, the court is respectfully urged to
review and approve the following voir dire questions submitted by the plaintiff:
l. Do you know any of the parties or witnesses?
2. Do you know any of the members of Parrett, Porto, Parese & Colwell?
3. Have you ever been to Las Vegas?
4. Have you ever sat on a jury before?
5. Have you ever been a party to a lawsuit?
6. Do you think that the payment of money is an appropriate way to compensate for
human pain and suffering?
7. Do you have any feelings about a person who comes to court and makes a claim
for money damages as compensation for injuries?
8. Do you object to awarding damages for pain and suffering?

Case 3:03-cv-01034-AVC Document 30 Filed O2/11/2005 Page 2 of 4
9. D0 you have any feelings one way or another about a person who was injured in
an accident and brings a lawsuit to recover money damages for those injuries?
10. Have you ever had a positive or negative experience with the judicial system
that would affect your ability to be fair to both sides of this case?
11. Do you or does anyone in your immediate family suffer from the following
clinically diagnosed psychological conditions: generalized anxiety disorder; post traumatic
stress disorder; or major depressive disorder?
12. Have you or anyone in your immediate family been exposed to neck or back
problems?
13. Do you have any particular expertise in prescription medications?
14. Can you fairly and impartially apply the law to the case as the judge instructs
you, even if that law runs contrary to what you believe the law should be?
15. Have you or anyone in your immediate family been the victim of an assault,
battery or other physical attack?
16. Do you have any biases toward people who treat with psychologist or other
mental health professionals?
17. Do you have any prejudicial feelings toward the field of mental health or
towards mental health professionals?
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Case 3:03-cv-01034-AVC Document 30 Filed O2/11/2005 Page 3 of 4
18. Is there any reason why you could not fairly and impartially evaluate a
psychological disability?
19. Do you have any biases toward physical therapists or the practice of physical
therapy?
20. Do you believe you could fairly award someone damages for an injury that was
made considerably more severe on account of that person’s preexisting vulnerability?
21. Would you feel any hostilities or prejudice toward the plaintiff because she is a
resident of the state of Texas?
22. Do you have any feelings about the national debate concerning tort reform?
22. What radio and television stations do you generally watch to get your news?
The Plaintiff, Darla Patton
By: '
OHN MICHAE PARESE
Parrett, Porto, Parese & Colwell, P.C.
2319 Whitney Avenue, Suite 1D
Hamden, CT 06518
Phone: (203) 281-2700
Fax: (203) 281—0700
Federal Bar No.: CT25291
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Case 3:03-cv-01034-AVC Document 30 Filed O2/11/2005 Page 4 of 4
ORDER
The foregoing Proposed Voir Dire Questions having been presented, ARE HEREBY
ORDERED:
APPROVED / DENIED.
THE COURT
BY:
JUDGE/CLERK
CERTIFICATION
This is to certify that a copy of the foregoing has sent via mail and facsimile this lik
day of February, 2005, to all counsel and parties of record as follows:
COUNSEL FOR James Cusano
Michael L. McDonnell, Esq.
700 Stanley Drive
New Britain, CT 06050
Facsimile No.: (860) 827-4386 / V
ohn Michael Parese
Parrett, Porto, Parese & Colwell, P.C.
2319 Whitney Avenue, Suite 1D
Hamden, CT 06518
Phone: (203) 281-2700
Fax: (203) 281-0700
Federal Bar No.: CT25291
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