Free Proposed Voir Dire - District Court of Colorado - Colorado

Case 1:04-cv-01067-MSK-CBS

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Filed 09/12/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO 04-cv-01067-MSK-CBS WILLIAM R. CADORNA, Plaintiff, v. CITY AND COUNTY OF DENVER, COLORADO, Defendant.

PLAINTIFF'S PROPOSED VOIR DIRE

Plaintiff William R. Cadorna hereby submits his proposed voir dire: 1. Do you agree that if a big city like Denver fires a Firefighter for a crime he did not commit, he should get his job back? 2. Do you agree that Firefighters are special because they do very dangerous things to help others? 3. Would you be willing to do a job that requires you to risk death or serious injury to help others? 4. Do you think it is good public policy to make sure that Firefighters can only be fired for just cause? 5. Do you think it is good public policy to make sure that Firefighters can't be fired unless they get full due process? 6. Tell us what you think "due process" means?

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7.

Would you do your best to make sure that a Firefighter is protected against having his property interest in his job taken away for no reason?

8.

Would you do your best to make sure that a Firefighter is protected against having his liberty interest in his job, career, or reputation taken away for no good reason?

9.

Do you think it is good public policy to make sure that Firefighters have a good retirement pension because what they do is so dangerous?

10.

Do you agree that just because a person retires doesn't mean he can't work any more?

11.

Do you agree that just because a person retires doesn't mean that he doesn't want to do his job any more?

12.

Do you agree that if a Firefighter is terminated without good cause, he should be put in the same position he would have been in if he had never been fired?

13.

Do you agree that, if an employer fires an employee without just cause, the employer should have to make the employee whole for all of the employee's losses?

14. 15.

Do you think employers discriminate against older people? Have you or anyone you know ever been discriminated against on the job? If so, tell us about it.

16.

Have you or anyone in your family ever sued someone? Why? What was the outcome? Were you happy or unhappy with the outcome? Why?

17.

Have you or someone in your family ever been sued? Why? What was the

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outcome? Were you happy or unhappy with the outcome? Why? 18. 19. Have you ever been a witness in a legal case of any kind? Tell us about it. Have you ever been fired from a job for a reason you thought was unfair? Tell us about it. 20. Have you ever been a victim of some kind of illegal discrimination? What kind? Tell us about it. 21. Do you think people who file discrimination complaints are just whiners trying to take advantage of the system? 22. Have you, or has anyone close to you, ever filed a grievance or an appeal from a job-related decision? Tell us about it. 23. Have you ever been accused of firing someone unfairly, or of some kind of illegal discrimination? Tell us about it. 24. Do you think any employer should be able to fire an employee for any reason the employer feels is best for its business or operations? 25. Have you taken any courses in human resources management, personnel practices, or labor relations? Tell us about it. 26. Have you ever, as part of your job, had the power to hire, discipline or discharge co-workers? Tell us about it. 27. Have you, or has anyone close to you, ever worked in the area of personnel or human resources? Tell us about it. 28. If the evidence in this case shows that Defendant violated Plaintiff's rights, would you be willing to award Plaintiff money to make him whole for the losses

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Defendant has caused him? 29. Would you hesitate to require Defendant to pay Plaintiff a lot of money because Defendant is a public employer? 30. 31. 32. Do you think that prosecutors only prosecute people who are guilty? Do you think that public prosecutors sometimes convict innocent people? Do you agree that government agencies and politicians can be just as dishonest and corrupt as private corporations? 33. Do you agree that Big Government is the biggest threat to our constitutional rights? 34. Do you agree that the Government has gone too far in invading our privacy and interfering with our civil rights in the name of fighting terrorism? 35. Do you agree that our country has drifted a long way away from what our Founding Fathers had in mind, and that Big Government and Big Business have become too powerful? 36. Are you more likely to believe what a manager or executive says, or what a worker says? 37. 38. 39. Do you like to read? What are some of your favorite books? What are your favorite television shows? What do you like about them? Do you think all plaintiff's lawyers are money-grubbing swine who are only in it for the money? 40. Do you think all defense lawyers are money-grubbing swine who would do anything to win, whatever the harm to little people?

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41.

Do you agree that, if it weren't for plaintiff's lawyers, most people would have no way to get justice in this country?

42.

Do you think that all defense attorneys are good guys just trying to protect employers against unfair lawsuits?

43.

Do you agree that one of the biggest problems in our country today is that employers get sued all the time even though they do their best?

44.

Do you agree that we need to put a stop to people being able to file so many lawsuits against employers?

45. 46. 47.

Who are your biggest heroes? Why? Who do you think were our greatest Presidents? Why? Who would you like to see as our next President? Why? DATED this 12th day of September, 2008.

Respectfully submitted,

/S/ Mark E. Brennan
Mark E. Brennan, P.C. P.O. Box 2556 Centennial, CO. 80161-2556 (303) 552-9550 (office) (303) 797-7687 (cell) Attorney for Plaintiff

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CERTIFICATE OF SERVICE The undersigned hereby certifies that, on this 12th day of September, 2008, he served a copy of the foregoing Plaintiff's Proposed Voir Dire upon the following person(s) via the Court's electronic filing system: Chris Lujan, Esq. Frank Nachman, Esq. Office of the City Atty. 201 W. Colfax, Dept. 1108 Denver, CO. 80202

/S/ Mark E. Brennan

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