Free Proposed Voir Dire - District Court of Connecticut - Connecticut

Case 3:01-cv-02345-JCH

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UNITED STATES DISTRICT COURT District of Connecticut -------------------------------------------------------X FRANK PORTO Plaintiff, V. METRO-NORTH RAILROAD COMPANY, Defendant. -------------------------------------------------------X APRIL 26, 2005 Case Number: 3:01CV02345(JCH)

DEFENDANT METRO-NORTH COMMUTER RAILROAD'S REQUESTED VOIR DIRE 1. Please state your name, age, occupation, spouse's occupation, whether you have

any children, their ages and occupations. 2. which union. 3. Have you or any member of your family ever been a party in any civil lawsuit? a. If so, could you briefly describe the circumstances of the lawsuit? b. Was there anything about that experience which would tend to make you biased or prejudiced in any way to any party? 4. Have you ever been involved in an accident in which you sustained any injury to Are you or any member of your family a member of a union? If so, please state

Case 3:01-cv-02345-JCH

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your body? 5. If so, a. describe the injury. b. describe the circumstances of the accident and injury. c. was a claim made? d. how was the claim resolved? e. was there anything about that experience which would cause you not to be objective in deciding this case? 6. Do you understand that under our system of justice, it is the burden of the plaintiff

to prove his case against the defendant? 7. As part of that, do you understand that the plaintiffs must prove that the accident

was caused as a result of the defendant's fault and that the decedent's death was the direct consequence thereof? 8. fault? 9. If at the end of this case you find that the defendant Metro-North Commuter Do you understand that the defendant does not have to prove that it wasn't at

Railroad was not responsible for the accident, could you return a verdict for the defendant MetroNorth? 10. Have you or any members of your family ever worked for Metro-North Commuter

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Railroad or any other railroad? 11. If so, a. which railroad? b. when did you or they work there? c. did you or they ever make a claim against the railroad for injuries sustained? d. is there anything about your or their employment on the railroad which would color your thinking in this case or cause you to be biased toward either one of the parties in this action? 12. Do you have any feelings, pro or con, concerning Metro-North Commuter

Railroad or any other railroad, which might cause you to be anything less than fair in deciding this case? 13. 14. your decision? 15. Have you ever sat on a jury before on a case that went to verdict? a. If so, what type of case was it? b. Was there anything about that experience which would prevent you from sitting on this jury and being fair and impartial to both sides? 15. Have you or anyone you know of had a knee or back injury? Can you be fair to all sides in this dispute and render a fair and impartial verdict? Will you be able to apply your common sense to the facts of this case in making

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16.

If so, would the knowledge you have of that knee or back injury impair your

ability to be fair and neutral in this case? 17. Will you be able to follow the letter of the law even if you personally do not agree

with the results or outcome that results from doing so?

THE DEFENDANT METRO-NORTH RAILROAD COMPANY,

BY_________________________________ Robert O. Hickey (19555) Ryan, Ryan, Johnson & Deluca, LLP 80 Fourth Street Post Office Box 3057 Stamford, CT 06905 Tel. No. 203-357-9200

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CERTIFICATE OF SERVICE I certify that I delivered a true and correct copy of the foregoing via Federal Express, to the following counsel and pro se parties of record: Charles C. Goetsch, Esq. Cahill & Goetsch, P.C. 43 Trumbull Street New Haven, CT 06511 this 13TH day of April, 2005.

_____________________________ Robert O. Hickey

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