Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:01-cv-02402-AWT

Document 105-2

Filed 05/29/2007

Page 1 of 2

EXHIBIT "A" Plaintiffs' List of Proposed Questions for Jury Panel Willingness/ Ability to Serve This trial is expected to last for up to several days. Is there anything about the length or scheduling of the trial that would interfere w/ your ability to serve? Do you have any medical, personal or financial problems that would prevent you from serving on this jury? Is there anything that would make it difficult for you to sit, listen, or deliberate for two hours without a break? Prior jury service Have you sat on a jury before (when/ location/ criminal/civil/ state/federal/ give details)? Do any of you have unpleasant associations with lawyers, judges, or the courts? If so, would it interfere w/ your ability to decide this case? Prior Lawsuits Have you or any family member or close personal friend ever filed a claim or lawsuit of any kind? Has anyone filed a claim against you, your family, or close friend? What was the outcome of that case? Were you satisfied that the outcome was fair? Were you ever a witness? Were you ever deposed? Prior Knowledge of case/ parties/ witnesses/ area Do you know any of the lawyers or the defendants? Do you know any of the potential witnesses?

Case 3:01-cv-02402-AWT

Document 105-2

Filed 05/29/2007

Page 2 of 2

Are you familiar w/ the areas and business I have described (the Pilot's Point Marina, Brewer Marina, etc.) or anyone who works there? I have already briefly described this case. Do you know anything about this case from any other source? Do you have any background in boats, boat design, or boat engines? Potential Prejudice Plaintiffs are people; the Defendant is a corporation. Do you have any bias toward Plaintiffs because they have filed a lawsuit against a corporate defendant? Have any of you purchased a new product (car, boat, etc.) that did not meet your expectations? How did the company resolve any problems? There has been a great deal of discussion in the media regarding "Tort Reform," and laws that restrict the right to sue or the potential discovery. Do you have any opinion on this subject? Do you believe it is wrong to bring a lawsuit? If the law and evidence warrant, would you be able to render a verdict in favor of the plaintiff or defendant regardless of any sympathy you might have? Can you accept the law as explained by the Court and apply it to the facts regardless of your personal beliefs about what the law is or should be? The purpose of questioning you as potential jurors is to select a fair and impartial jury. Is there anything not covered in the previous questions that would affect your ability to act as such? Boating knowledge/ Knowledge of Sea Ray Are you familiar w/ boats/ power boats/ and or sail boats? (Sailboat owners tend to have negative feelings toward powerboats and powerboat owners). Do any of you own a boat, if so, what kind, make, model, etc.? Have you or do you own a Sea Ray boat? (Make/ year/ model). What experience have you had with Sea Ray?