Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:01-cv-02313-RNC

Document 125-3

Filed 09/08/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CARLEEN AHERN v. TRANSUNION LLC Case No. 3:01CV 2313 (RNC)

PLAINTIFF' PROPOSED VOIR DIRE QUESTIONS S
PLAINTIFF OBJECTS TO TRANS UNION' PROPOSED QUESTIONS BECAUSE THEY S ARE LARGELY RELATED TO THE JUROR' PERSONAL CREDIT MATTERS, S CONSTITUTE AN UNNECESSARY INVASION OF PRIVACY, AND HAVE NOTHING TO DO WITH POSSIBLE BIAS OR PREJUDICE AS TO TRANS UNION OR THIS MATTER. DEFENDANT' ATTEMPT TO EXCLUDE MOST OF THE POTENTIAL JURORS S SHOULD BE REJECTED. PLAINTIFF IS ENTITLED TO A JURY OF HER PEERS.

(In addition to standard questions as to whether they know the parties/ attorneys/ witnesses/ have prior jury experience or have ever been party to a lawsuit) 1. Are you or have you been in a business which obtains consumer credit reports, for instance, to extend credit or collect debts? 2. Do you have any family or household members or close friends who are or have been in a business which obtains consumer credit reports to extend credit or collect debts? 3. Have you or has anyone in your family or friends worked for Credit Bureau of Connecticut in West Haven? 4. Are you or have you been in a business which sells credit reports? 5. Do you have any family or household members or close friends who are or have been in such a business? 6. Have you been employed by Trans Union? 7. Have any family members or close friends been employed by Trans Union? 8. If you determine that Trans Union has violated the Fair Credit Reporting Act,
is there any reason you would NOT be willing to award damages to Carleen Ahern for her

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Case 3:01-cv-02313-RNC

Document 125-3

Filed 09/08/2004

Page 2 of 2

emotional distress in accordance with the instructions given to you by the Court?

9. If you find that Trans Union violated the Fair Credit Reporting Act, is there any reason you would NOT be willing to award statutory damages even if Carleen Ahern had no actual damages for emotional distress and the like? 10. If you determine that Trans Union has willfully violated the Fair Credit Reporting Act, would you, for any reason, NOT be willing to award punitive damages to Carleen Ahern in accordance with the instructions given to you by the Court? 11. Is there any reason that you could not sit and hear this case and render a verdict, in accordance with instructions given by the Court, which would be fair to both the plaintiff and the defendant under the evidence as it may be presented? 12. Do you have any philosophical, religious, or other belief that would prevent you from sitting in judgment on a case? 13. Do you have any health problems, such as hearing or eyesight, or any need to take medication which would interfere with your ability to sit as a juror on this case? 14. Could you not be fair and impartial, for any reason, whether for some reason that has already been discussed or any reason that has not been discussed, such as your beliefs or convictions about individuals, corporations, or the jury system?

Trans Union objects to Plaintiff's proposed voir dire to the extent plaintiff references damages and punitive damages. Such matters ought not to be before the panel unless and until the Court rules upon the outstanding "anticipated discovery issues."

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