Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:01-cv-02063-PCD

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Filed 12/15/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : Plaintiffs : : VS. : : MARON CONSTRUCTION, CO., INC. : and RONALD DEFRANCESCO : : Defendants : JOSEPH STRYCHASZ, SANDRA STRYCHASZ and MIDLAND FIRE PROTECTION COMPANY CIVIL ACTION NO.: 3:01CV2063 (PCD)

DECEMBER 15, 2003

DEFENDANTS= PROPOSED VOIR DIRE QUESTIONS In compliance with Section C9 of the Court=s October 27, 2003 Trial Preparation Order, the defendants herein submit their proposed voir dire questions.

1.

Has anyone here sustained an injury on the premises of If so, please explain

another that required medical attention?

the circumstances under which the accident occurred and whether a claim was made as a result of that accident. 2. Has anyone here been injured in the context of an If so, please explain the circumstances

automobile accident?

under which the accident occurred and whether a claim was made as a result of that accident.

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3.

Has anyone here been injured while at work which

resulted in either medical attention being necessary or loss of time from work? If so, please explain the circumstances under

which this occurred and whether a Workers= Compensation claim was made. 4. Has anyone here sustained an injury to his or her If so, please

wrists, legs, knees, ankles, heels or feet?

indicate whether this injury required the need for surgical intervention and whether is arose as a result of an accident. 5. Has anyone here had a family member or a close friend

who sustained an injury to his or her wrists, legs, knees, ankles, heels or feet that required medical attention, hospitalization and/or surgical intervention? If so, please

explain the your relationship with that person and, in summary form, the nature of those medical problems. 6. Has anyone here lost time from work due to injuries or If so, please explain the length of time

medical conditions?

you were disabled from work, the reasons why and whether a claim for disability was made.

7.

Has anyone here filed a lawsuit seeking monetary

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damages for injuries sustained?

If so, please explain the

nature of the claim, when the claim was made, whether the claim is still pending or the circumstances under which it was resolved. 8. Has anyone here been sued by someone else (in other If so, please

words, been the defendant in a civil proceeding)?

explain the circumstances associated with that claim, whether it is still pending or how it was resolved. 9. Does anyone here possess the opinion that there are

too many lawsuits or that many of the suits that are filed are without basis? 10. Please explain.

Does anyone here possess the belief that just because

a lawsuit has been brought, the plaintiff must be entitled to some amount of compensation, even if it is less than he or she ask for? 11. Please explain. Do any members of the panel believe that there are

accidents which happen for which no one is legally at fault B- in other words, that sometimes people are injured under circumstances which were not foreseeable? If so, please explain.

12.

Does anyone here have difficulty with following an

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instruction that would require you to decide this case based only upon the facts and the law, without regard for sympathetic feelings or emotional response toward a party? 13. Would anyone here have difficulty turning the

plaintiff away without the award of money damages if that is what the evidence and the law would require, even if it were the case that this made you feel badly or where you knew that the plaintiff had sustained a physical injury or other hardship? 14. Has anyone here had the experience of working on a If so, please

construction site or for any construction trade?

explain the experience that you possess, the trade and role played on that construction site. 15. Is anyone here a member of a union? If so, please

share with us what union, as well as your experience associated with membership in this union. 16. Does anyone here have experience as a sprinkler fitter If so, please summarize your experience and the

or pipe fitter?

types of jobs worked at within this field. 17. Does anyone here have engineering experience or If so, please explain.

architectural experience? 18.

Does anyone here have any experience working for a

governmental agency or a branch of the military, even if in a

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civilian capacity?

If so, please explain the experience and

your job or role for that government agency or entity. 19. Does anyone here have experience associated with If so, please explain.

building maintenance or repair? 20.

Does anyone here either own a business that is held or If so, please explain. If

operated by his or her family? 21.

Does anyone here work for a family-run business?

so, please explain. 22. Are any panel members self-employed? If so, please

explain the nature of your business, the approximate number of employees who work for you and the length of time that you have been self-employed. 23. Has anyone here ever received Social Security

Disability benefits, private disability benefits or Workers= Compensation benefits? 24. 25. If so, please explain.

Is anyone here presently unemployed? Has anyone here ever been injured in an incident for

which he or she believed he or she could have made a claim or filed a lawsuit, but chose not to? If so, please explain.

THE DEFENDANTS, MARON CONSTRUCTION COMPANY, INC. AND RONALD DeFRANCESCO BY MILANO & WANAT LLC

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By

Mark A. Milano (CT 1062) Milano & Wanat LLC 471 East Main Street Branford, Connecticut 06405 (203)315-7000

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CERTIFICATE OF SERVICE

This is to certify that the foregoing has been mailed, this date, postage prepaid, on this to the following: For the plaintiff, Joseph Strychasz Edward Gavin, Esquire Meehan & Meehan 76 Lyon Terrace Bridgeport, Connecticut 06604 For the plaintiff, Midland Fire Protection Company Gregory Goodstein, Esquire Morrison, Mahoney & Miller One Constitution Plaza Hartford, Connecticut 06103-1810 day of December, 2003

Mark A. Milano