Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:02-cv-01302-JCH

Document 509

Filed 12/13/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SHAWN POULIOT Plaintiff v. PAUL ARPIN VAN LINES, INC. et al. Defendants : : : : : : : : :

CIVIL ACTION NO. 3:02 CV 1302 (JCH) JUDGE JANET C. HALL

December 6, 2005

DEFENDANTS PAUL ARPIN VAN LINES, INC.'S AND ARPIN LOGISTICS, INC.'S PROPOSED JURY INTERROGATORIES PURSUANT TO PARAGRAPH 15(b)(3) OF FINAL PRETRIAL ORDER

1.

Do you find that the ARPIN Defendants were negligent as to Plaintiff, SHAWN

POULIOT? YES NO

If your answer to Question #1 is yes, please proceed to Question #2. If your answer to Question #1 is no, please proceed to Question #3. 2. Was the negligence of the ARPIN Defendants a substantial factor in causing the

injuries sustained by Plaintiff, SHAWN POULIOT? YES NO

If your answer to Question #2 is yes, please proceed to Question #3. If your answer to Question #2 is no, please proceed to the last page and have the foreperson sign and date this form.

3.

Do you find that the apportionment Defendant, FESTO CORPORATION, was

negligent as to Plaintiff, SHAWN POULIOT? YES NO

If your answer to Question #3 is yes, please proceed to Question #4. If your answer to Question #3 is no, please proceed to Question #5.

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Case 3:02-cv-01302-JCH

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4.

Was the negligence of the apportionment Defendant, FESTO CORPORATION, a

substantial factor in causing the injuries sustained by Plaintiff, SHAWN POULIOT? YES Please proceed to Question #5. 5. Do you find that the apportionment Defendant, TRANS-EXPO NO

INTERNATIONAL, was negligent as to Plaintiff, SHAWN POULIOT? YES NO

If your answer to Question #5 is yes, please proceed to Question #6. If your answer to Question #5 is no, please proceed to Question #7. 6. Was the negligence of the apportionment Defendant, TRANS-EXPO

INTERNATIONAL, a substantial factor in causing the injuries sustained by Plaintiff, SHAWN POULIOT? YES Please proceed to Question #7. 7. Do you find that Plaintiff, SHAWN POULIOT, was negligent? YES NO NO

If your answer to Question #7 is yes, please proceed to Question #8. If your answer to Question #7 is no, please proceed to Question #9. 8. Was the negligence of Plaintiff, SHAWN POULIOT, a substantial factor in

causing the injuries he sustained? YES Please proceed to Question #9. 9. Taking all of the combined negligence that was a substantial factor in bringing NO

about the injuries sustained by Plaintiff, SHAWN POULIOT, as 100%, please state what percentage of that negligence is attributable to each of the following: 2

Case 3:02-cv-01302-JCH

Document 509

Filed 12/13/2005

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(a) (b) (d)

ARPIN Defendants Apportionment Defendant, FESTO CORPORATION Apportionment Defendant, TRANS-EXPO INTERNATIONAL Plaintiff, SHAWN POULIOT Total Percentage

% %

______ % % 100 _%

(e)

If the percentage attributed to Plaintiff, SHAWN POULIOT, in Question #9(e) is greater than 50%, answer no more questions, and please proceed to the last page and have the foreperson sign and date this form. If the percentage attributed to Plaintiff, SHAWN POULIOT, is 50% or less, please proceed to Question #10.

10.

Do you find that the ARPIN Defendants were reckless as to Plaintiff, SHAWN

POULIOT? YES Please answer Question #11. 11. Please state the amount of compensatory damages sustained by Plaintiff, SHAWN POULIOT: (a) For the total amount of medical care that was reasonable and necessary and related to the injuries sustained by Plaintiff, SHAWN POULIOT: For the total amount of Plaintiff, SHAWN POULIOT'S earnings lost as a result of his injuries: For the mental and physical pain and suffering of Plaintiff, SHAWN POULIOT as a result of his injuries: Total Damages of Plaintiff, SHAWN POULIOT Please proceed to Question #12. NO

$

(b)

$

(c)

$ $

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12.

Multiply the percentage of negligence of ARPIN Defendants as set forth in

Question #9(a) by the Total Damages of Plaintiff, SHAWN POULIOT, as set forth in the last line of Question #11. $ (This is your verdict)

The foreperson should sign and date this form where indicated upon completion, and return it to the Bailiff.

__________________________ Foreperson

__________ Date

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CERTIFICATE OF SERVICE This is to certify that a copy of Defendants Paul Arpin Van Lines, Inc. and Arpin Logistics, Inc.'s Proposed Jury Interrogatories Pursuant to paragraph 15(b)(3) of Final Pretrial Order was mailed via U.S. First Class Mail this 6th day of December, 2005 to the following:

Michael A. Stratton, Esq. Stratton Faxon 59 Elm Street New Haven, CT 06510 Thomas J. Grady, Esq. Lenihan Grady & Steele 6 Canal Street PO Box 541 Westerly, RI 02891-0541 Daniel J. Krisch, Esq. Horton, Shields & Know, P.C. 90 Gillett Street Hartford, CT 06105

Roland F. Moots, Jr., Esq. Moots, Pellegrini, Spillane & Mannion 46 Main Street, PO BOX 1319 New Milford, CT 06776-1319

/s/ Harold J. Friedman Harold J. Friedman, Esq. CT 23785

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