Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:03-cv-01025-EBB

Document 18

Filed 08/03/2004

Page 1 of 5

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ARNOLD L. WHITAKER Plaintiff VS. WAYNE BULLOCK, MICHAEL PUNZO & SCOTT DURKIN Defendants : : : : : : : :

CIVIL NO. 3:03 CV 1025 (EBB)

AUGUST 3, 2004

DEFENDANTS' PROPOSED VOIR DIRE QUESTIONS Counsel for the defendants in the above-captioned matter respectfully requests that the following questions be asked of potential jurors: 1. Have you, or anyone you know, ever been arrested or seized by a police officer? a) If so, please state: i) whether the person arrested or seized was you or someone else and, if not you, state that person's relationship to you; ii) iii) b) the circumstances of the arrest or seizure; and which police department was involved.

If your answer to the first questions was "yes," what was your impression of the conduct of the police at the time?

OFFICE OF THE CORPORATION COUNSEL · CITY OF NEW HAVEN 165 Church Street, New Haven, CT 06510 Telephone (203) 946-7958 · Facsimile (203) 946-7942 · Juris No. 42715

Case 3:03-cv-01025-EBB

Document 18

Filed 08/03/2004

Page 2 of 5

2.

Have you, or anyone you know, ever been harassed, assaulted or verbally abused

by a police officer? a) If so, please state: i) whether the person harassed, assaulted or verbally abused was you or someone else and, if not you, state the person's relationship to you; ii) iii) b) the circumstances of the harassment, assault or verbal abuse; and which police department was involved.

If your answer to the second questions was "yes", what was your impression of the conduct of the police at the time?

3.

Have you ever witnessed an incident in which you felt that a police officer was

harassing, assaulting or verbally abusing another person? a) If so, please state: i) ii) b) the circumstances of the harassment, assault or verbal abuse; and which police department was involved.

If your answer to the third question was a "yes," what was your impression of the conduct of the police at the time?

OFFICE OF THE CORPORATION COUNSEL · CITY OF NEW HAVEN 165 Church Street, New Haven, CT 06510 Telephone (203) 946-7958 · Facsimile (203) 946-7942 · Juris No. 42715

Case 3:03-cv-01025-EBB

Document 18

Filed 08/03/2004

Page 3 of 5

4.

Have you ever been a party to or witnessed an incident in which you felt that a

police officer or officers acted improperly or without just cause? a) If so, please state: i) ii) b) the circumstances of the incident; which police department was involved.

If your answer to the fifth question was "yes," what was your impression of the conduct of the police at the time?

5.

Are you now, or have you ever been employed by a law enforcement or security

agency? a) If so, please state: i) ii) the nature of said employment, and whether this would affect your ability to be a juror in a case involving a police officer. 6. Do you have any relatives or close friends who are now employed, or have been

employed by a law enforcement or security agency? a) If so, please state: i) the nature of your relationship with this person or persons;

OFFICE OF THE CORPORATION COUNSEL · CITY OF NEW HAVEN 165 Church Street, New Haven, CT 06510 Telephone (203) 946-7958 · Facsimile (203) 946-7942 · Juris No. 42715

Case 3:03-cv-01025-EBB

Document 18

Filed 08/03/2004

Page 4 of 5

ii) iii)

the nature of the employment; and whether this would affect your ability to be a juror in a case involving a police officer.

7.

Have you, or any member of your family or any acquaintance ever been employed

by any government agency? a) If your answer to the foregoing question is "yes," do you feel such person was fairly treated by that employer, and if not, why not? b) Do you believe that anything about that experience or involvement might affect your ability to judge this case fairly, and if so, in what way? 8. Have you, or any member of your family or close friend, ever belonged to any civil

rights or civil justice organization? a) b) If so, please provide details, including the name of the organization. Do you believe that anything about that membership might affect your ability to judge this case fairly? If so, in what way? 9. During the past few years there have been reports in newspapers and on

television and radio about incidents involving police officers and members of the public. Do any of you believe that what has been reported would influence you in any way if you were chosen to sit on a jury where misconduct by a police officer has been alleged?

OFFICE OF THE CORPORATION COUNSEL · CITY OF NEW HAVEN 165 Church Street, New Haven, CT 06510 Telephone (203) 946-7958 · Facsimile (203) 946-7942 · Juris No. 42715

Case 3:03-cv-01025-EBB

Document 18

Filed 08/03/2004

Page 5 of 5

a)

If you answer is yes, have you formed any opinions or drawn any conclusions about police officers in general that might affect your ability to judge this particular case fairly? THE DEFENDANTS

BY:________________________ Jonathan H. Beamon Assistant Corporation Counsel Federal Bar No. ct22937 City of New Haven 165 Church Street, 4th Floor New Haven, CT 06510 (203) 946-7958 E-mail: [email protected]

CERTIFICATION I hereby certify that a copy of the foregoing was mailed on August 3, 2004 to the following counsel of record, to wit: Dawne Westbrook, Esq. P.O. Box 2502 Middletown, CT 06457 ___________________________ Jonathan H. Beamon

OFFICE OF THE CORPORATION COUNSEL · CITY OF NEW HAVEN 165 Church Street, New Haven, CT 06510 Telephone (203) 946-7958 · Facsimile (203) 946-7942 · Juris No. 42715