Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:01-cv-02146-AWT

Document 49-5

Filed 04/04/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT GARY BEDOR : : : v. : : FRIENDLY ICE CREAM : CORPORATION, : Defendant. : ________________________________: Plaintiff, CIVIL ACTION NO. 301CV2146 (AWT)

March 29, 2006

PLAINTIFF'S PROPOSED VOIR DIRE QUESTIONS 1. Do you know any of the lawyers or law firms involved in this case, or have you or

any close friend or relative ever been a client of either of the law firms? a. If so, please explain the nature of the relationship and state whether you have any feelings that would make it difficult for you to fairly and objectively render a verdict for or against that lawyer's client.

2.

Do you know the Plaintiff in this case, Gary Bedor? a. If so, please explain how you know him and state whether you have any feelings that would make it difficult for you to fairly and objectively render a verdict for or against Mr. Bedor.

3.

Have you ever been employed by or had a business relationship with the

Defendant in this case, Friendly Ice Cream Corporation? a. If so, please explain the nature of your relationship with the Defendant and state whether you have any feelings that would make it difficult for you to fairly and objectively render a verdict for or against Friendly Ice Cream Corporation.

4.

Do you know any of the following individuals who may be called as

witnesses or whose name may come up on this case: Richard Damarjian Perry Phillips Thomas Cebula Marie Bedor

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Gary Glenn Robin Binall Gary Geiger Ron Oliver Angela Mastropolo Vincent Laudone, MD. a.

Michael Maglioli Kenneth Milley Richard Cutter John Cotter Cheryl Hutchinson

If so, please explain the relationship and state whether you have any feelings that would make it difficult for you to fairly and objectively evaluate any testimony given by that person.

5.

Have you, a relative, significant other, or close friend ever been fired, laid

off, or otherwise involuntarily terminated from employment? a. If so, please explain the circumstances.

6.

Have you or any close friend or relative ever been employed in the

personnel, human resources, or labor relations field for a corporation or for a governmental agency? a. If so, please state when you or the close friend or relative held the position and describe the nature and duties of the position.

7. Have you or any close friend or relative ever been in a supervisory position? a. If so, please state when you or the close friend or relative held the position and describe the nature and duties of that position.

8.

Have you or a close friend or relative ever terminated an employee? a. If so, please state the circumstances under which you terminated the employee and the reasons for the termination. 2

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9.

Have you or any close friend or relative ever been accused of discrimination or

retaliation with respect to employment? a. If so, please describe the circumstances of such accusation.

10.

Have you or any close friend or relative ever taken a medical leave under the

FMLA? a. If so, please state whether you have any feelings about the leave that would make it difficult for you to fairly and objectively evaluate this case.

11.

Have any of your co-workers ever taken a medical leave under the

FMLA? a. If so, please state whether you have any feelings about the leave that would make it difficult for you to fairly and objectively evaluate this case.

12.

Have you or any close friend or relative ever had a disability that affected them

at work, either because they needed a medical leave or a work accommodation or because they believed that they were discriminated against at work? a. If so, please state whether you have any feelings about the leave that would make it difficult for you to fairly and objectively evaluate this case. 13. Have any of your co-workers ever had a disability that affected them at work? a. If so, please state whether you have any feelings about this would make it difficult for you to fairly and objectively evaluate this case.

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14.

Do you have any opinion about employees who bring lawsuits against their

employers? a. 15. If so, please describe those opinions.

Have you or any close friend or relative ever been involved in a lawsuit as a

party, a witness or a juror? a. b. c. If you were a party, were you a Plaintiff or a Defendant? What type of case? What was the result? If you were a witness, what type of case? For which side did you testify? What was the result? If you were a juror, did the case go to a verdict? What type of case? What was the verdict?

16.

Would you have any difficulty awarding the Plaintiff damages for

emotional distress if you were satisfied that he was entitled to them?

17.

Would you have any difficulty awarding damages to punish an employer or deter

future illegal conduct if you were satisfied that such an award should be made?

18.

If you are currently employed, please state the position held, the name and

location of the employer, and the length of your employment.

19.

If you are not currently employed, please state the last position you held, the

name and location of the employer, and the length of your employment.

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20.

If you have a spouse or partner who is currently employed, please state the

position held, the name and location of the employer, and the length of his or her employment.

21.

If you have a spouse or partner who is not currently employed, please state the

last position he or she held, the name and location of the employer, and the length of his or her employment.

22.

If you have a child or children who are currently employed, please state his, her

or their position held, the name and location of the employer, and the length of employment.

23.

If you have a child or children who are not currently employed, please state

position held, the name and location of the employer, and the length of employment. RESPECTFULLY SUBMITTED, FOR THE PLAINTIFF, By: ________/s/______________ Thomas W. Meiklejohn ct08755 Mary E. Kelly ct07419 Livingston, Adler, Pulda, Meiklejohn & Kelly, P.C 557 Prospect Avenue Hartford, CT 06105 (860) 233-9821

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CERTIFICATE OF SERVICE This hereby certifies that the foregoing Plaintiff's Proposed Voir Dire Questions was hand delivered on this 29th day of March 2006 to all counsel of record as follows: Warren L. Holcomb Floyd J. Dugas Berchem, Moses & Devlin, P.C. 75 Broad Street Milford, CT 06460

_______/s/________________ Thomas W. Meiklejohn