Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:01-cv-02166-JCH

Document 135

Filed 02/28/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DUANE ZIEMBA v. CAPTAIN DeGRAY

: : :

CIVIL NO. 3:01CV2166 (JCH)

FEBRUARY 27, 2006

DEFENDANT'S PROPOSED VOIR DIRE QUESTIONS The defendant respectfully requests that the following questions be posed to prospective jurors: 1. This is a civil rights lawsuit where the plaintiff, an inmate, has alleged that the defendant, a correctional officer employed by the State of Connecticut, Department of Correction, used excessive force against him during an incident on March 4, 1999, at Northern Correctional Institution. Is there any reason why you would have any difficulty being completely fair and neutral in deciding this case if you were chosen to serve on this jury? If so, please explain. 2. Have you, or any member of your family, ever been a party to a lawsuit? If so, please describe the circumstances surrounding the lawsuit. 3. Have you ever served on a jury before? If so, please identify the Court you were in, the nature of the case on which you served and state whether a verdict was reached.

Case 3:01-cv-02166-JCH

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Filed 02/28/2006

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4.

Have you, or any member of your family, or close friend, ever been involved in what you consider to be a negative or unpleasant experience with the Department of Correction or any employee of the Department of Correction? If so, please explain. Do you feel that this experience would influence your ability to be neutral and fair in deciding this case?

5.

Have you or any member of your family had any interaction with employees of the Department of Correction?

6.

Have you, or any member of your family, or close friend, ever been arrested? If so, do you feel that this experience would influence your ability to be neutral and fair in deciding this case?

7.

Have you, or any member of your family, or close friend, ever spent any time in jail, or visit someone in jail? If so, please explain the circumstances and state whether this experience would influence your ability to be neutral and fair in deciding this case.

8.

Do you know anyone who is in prison? If yes, what is your relationship with that person? What is that person incarcerated for and how long is his/her sentence?

9.

Have you, or any member of your family, or close friend, ever filed a complaint against a police officer or correctional officer?

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Case 3:01-cv-02166-JCH

Document 135

Filed 02/28/2006

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If yes, please describe the circumstances surrounding the complaint and the outcome thereof. 10. 11. Does anyone here have any belief that correctional officers are incompetent? Have you read anything in the newspapers or saw anything on the television about the use of excessive force or brutality against inmates? If yes, were these stories concerning the Connecticut Department of Correction? And, if so, could you judge this case solely on the evidence presented in the Courtroom and put out of your mind anything you may have read or saw outside of the Courtroom? 12. Have you heard or read anything about the Department of Correction or its employees which would in any way interfere with your ability to be objective and impartial in this case?

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Case 3:01-cv-02166-JCH

Document 135

Filed 02/28/2006

Page 4 of 4

DEFENDANT Kevin DeGray RICHARD BLUMENTHAL ATTORNEY GENERAL

BY: ______/s/______________________________ Matthew B. Beizer Assistant Attorney General 110 Sherman Street Hartford, CT 06105 Federal Bar #ct16304 E-Mail: [email protected] Tel: (860) 808-5450 Fax: (860) 808-5591

CERTIFICATION I hereby certify that a copy of the foregoing was mailed to the following this 27th day of February, 2006: Duane Ziemba #128963 Garner Correctional Institution 50 Nunnawauk Road P.O. Box 5500 Newtown, CT 06470

______/s/____________________________ Matthew B. Beizer Assistant Attorney General

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