Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:01-cv-02129-AVC

Document 83

Filed 01/07/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DEBRA COSENTINO, ET AL, Plaintiffs, v. PITNEY BOWES, INC. and IMAGISTICS INTERNATIONAL, INC., Defendants. : PLAINTIFFS' PROPOSED VOIR DIRE QUESTIONS Plaintiffs submit the following proposed voir dire questions pursuant to the pretrial order and D.Conn. Local R. 47(a). 1. 2. Please tell us your educational background. (To employed venire persons only) please tell us a little bit, just a thumbnail sketch, of what you do every day at work. 3. (To venire persons who are not employed) please give us some idea, just a sketch, of your favorite activities. What do you enjoy? 4. Do you read any daily newspapers? If so, what are they DECEMBER ____ 2004 : : : CONSOLIDATED CASES : : 301CV2129 (AVC)

and what are your favorite parts to read?

Case 3:01-cv-02129-AVC

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5.

Do you watch TV?

If so, what are your favorite pro-

grams, and what do you like about them? 6. Have you, or any member of your family or close friends, ever brought a lawsuit? it. 7. If so, tell us about

What stands out in your mind about the experience?

Have you, or any member of your family or close friends, ever been sued? If so, tell us about it.

What stands out in your mind about the experience? 8. Have you, or any member of your family or close friends, ever thought about bringing a lawsuit? tell us about it. the experience? 9. Have you, or any member of your family or close friends ever owned a business? If so, tell us about it. What If so,

What stands out in your mind about

stands out in you mind about the experience? 10. Have you, or any member of your family or close friends, ever been let go from a job? If so, what

stands out in your mind about the experience? 11. Have you, or any member of your family or close friends, ever let anyone go from a job? If so, what

stands out in your mind about the experience?

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12. 13.

Are you a union member?

Tell us about it.

Do you, or any member of your family or close friends, have any strong feelings about unions? them. Tell us about

14.

Have you, or any member of your family or close friends, ever filed a union grievance? If so, what

stands out in your mind about the experience? 15. Have you, or any member of your family or close friends, ever a union grievance filed against them? If

so, what stands out in your mind about the experience? 16. Have you ever given the laws on employment discrimination any thought? If so, what comes up in

your mind when you think about them? 17. Have you ever felt that you were being discriminated against at work or in some other situation? about it. 18. To your knowledge have any members of your family or close friends ever been discriminated against? If so, tell us

what stands out in your mind about the experience?

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Case 3:01-cv-02129-AVC

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19.

Have you ever seen someone who wasn't close to you being discriminated against? Does anything stick out

in your mind about the experience? 20. Has anyone ever accused you, or any member of your family of close friends, of discrimination against them? tell us about it. What sticks out in your mind

about the experience. 21. Have you, or any member of your family or close friends, supervised people on the job? little about it. Tell us a

What sticks out in your mind about

supervising people? 22. Have you, or any member of your family or close friends, ever been the victim of a crime? little about it, if you can. you with any strong feelings? mind? Tell us a

Did the experience leave What sticks out in your

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Case 3:01-cv-02129-AVC

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Filed 01/07/2005

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THE PLAINTIFFS DEBRA COSENTINO, ET AL

By:_______________________ WILLIAM B. BARNES, ESQ. (CT00268) Rosenstein & Barnes P.O. Box 687 1100 Kings Hwy. East, Fairfield, CT 06824 (203) 367-7922 E-Mail [email protected] CERTIFICATION A copy of the foregoing was faxed and mailed to the following persons on December ____, 2004: Lawrence Peikes, Esq. Wiggin & Dana, LLP 400 Atlantic St., P.O. Box 110325 Stamford, CT 06911-0325 ______________________________ WILLIAM B. BARNES, ESQ.

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