Free Proposed Voir Dire - District Court of Colorado - Colorado

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

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO 04-cv-1067-REB-CBS WILLIAM R. CADORNA, Plaintiff, v. CITY AND COUNTY OF DENVER, COLORADO, JAMES A. SESTRICH, KELLEY S. CALDWELL, JOSEPH R. HART and FRANK J. HOFFMAN, Defendants.

PLAINTF ' P O O E V I DR IFS R P S D O R IE

Plaintiff William R. Cadorna hereby submits his proposed voir dire: 1. Do you agree that Firefighters are special because they do very dangerous things to help others? 2. Do you agree that Firefighters deserve special treatment because they do very dangerous things to help others? 3. Would you be willing to do a job that requires that you run into burning buildings and risk death or serious injury for about what a school teacher makes? 4. Do you think that a Firefighter who has worked for the City of Denver for 27 years gets paid too much, or not nearly enough, if he makes $60,000 a year? 5. Do you think it is good public policy to make sure that Firefighters can only be fired for just cause?

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6.

Do you think it is good public policy to make sure ta Frf hes a ' efe h t i i tr c n b i d eg t r unless they get full due process, c d gfl a g sfh y i ' ow a w s i l i u d ma e i e d n d h t a nun l t dt used as the excuse for firing them?

7. 8.

T l s h t o ti "u po e s me n ? e u w a y u h k d e rc s" a s l n If you were told that Firefighters have a property interest in their jobs that is protected by the United States Constitution, 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?

9.

If you were told that Firefighters have a liberty interest in their jobs, careers and reputation that is protected by the United States Constitution, 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?

10.

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?

11.

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?

12.

Do you agree that just because a person retires after he'fe d e n me nh si d o s' a e r t c n w r a y r? a ' ok n moe t

13.

Do you agree that just because a person retires after he'ldof ri dd e n sa fo fe o s ' i r t me nta h d e n w n t d h j a y a h t e o s ' a to o i o n more? t s b

14.

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?

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15. 16.

Do you agree that employees should only be terminated for just cause? Do you agree that, if an employer fires an employee without just cause, the e l e s o l h v t ma etee l e w o fr l fh e l e ' mp y r h u a e o k h mp y e h l o a o te mp y e o d o e l o s economic and emotional damages?

17. 18.

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

19.

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

20.

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

21. 22.

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.

23.

Have you ever been a victim of some kind of illegal discrimination? What kind? Tell us about it.

24.

Do you think people who file discrimination complaints are just whiners trying to take advantage of the system?

25.

Have you, or has anyone close to you, ever filed a grievance or an appeal from a job-related decision? Tell us about it.

26.

Have you ever been accused of firing someone unfairly, or of some kind of illegal discrimination? Tell us about it.

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27.

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?

28. 29.

Do you agree that employees should only be terminated for just cause? Have you taken any courses in human resources management, personnel practices, or labor relations? Tell us about it.

30.

Have you ever, as part of your job, had the power to hire, discipline or discharge co-workers? Tell us about it.

31.

Have you, or has anyone close to you, ever worked in the area of personnel or human resources? Tell us about it.

32.

If the evidence in this case shows that Defendant violated Plaintiff'r hs w u si t ol g , d you be willing to award Plaintiff a lot of money to make him whole for the losses Defendant has caused him?

33.

Would you hesitate to require Defendant to pay Plaintiff a lot of money because Defendant is a public employer?

34. 35. 36.

Do you think that public prosecutors only prosecute people who are guilty? Do you think that public prosecutors sometimes send innocent men to prison? Do you agree that government agencies and politicians can be just as dishonest and corrupt as private corporations?

37.

Do you agree that Big Government is the biggest threat to our constitutional rights?

38.

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?

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39.

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?

40.

Are you more likely to believe what a manager or executive says, or what a worker says?

41. 42.

Do you like to read? What are some of your favorite books? Do you like the books of Charles Dickens? Why? Which is your favorite Dickens book?

43. 44. 45.

Have you traveled much in your life? What are your favorite places to visit? What are your favorite television shows? What do you like about them? Do you think shows on TV that portray prosecutors and police as always honest and dedicated to the public interest are accurate, or fairy tales for the masses?

46.

Do you think all p i is ln f lawyers are money-grubbing swine who are only in it for a t' f the money?

47.

Do you think all defense lawyers are money-grubbing swine who would do anything to win, whatever the harm to little people?

48.

D y ua reta, i ee ' o p i isa y r, s p o l w u h v n o o ge h tit rn fr ln f l es mo t e p o l a e o fw t a t' w f e d way to get justice in this country?

49.

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

50. 51.

Do you agree that we have the best system of justice money can buy? Do you agree that one of the biggest problems in our country today is that

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employers get sued all the time even though they do their best? 52. Do you agree that we need to put a stop to people being able to file so many lawsuits against employers? 53. 54. 55. 56. Who are your biggest heroes? Why? Who do you think were our greatest Presidents? Why? Who did you vote for in the last Presidential election? Why? Who would you like to see as our next President? Why? DATED this 12th day of June, 2006. Respectfully submitted,

/S/ Mark E. Brennan
Mark E. Brennan, P.C. P.O. Box 2556 Centennial, CO. 80161-2556 (303) 552-9394 (office) (303) 797-7687 (cell) Attorney for Plaintiff

CERTIFICATE OF SERVICE The undersigned hereby certifies that, on this 12th day of June, 2006, he served a copy of the foregoing Pa t 'Po o e Voir Dire upon the following person(s) via lnis rp s d if f teC ut electronic filing system: h o rs ' Jack Wesoky, Esq. Chris Lujan, Esq. Office of the City Atty. 201 W. Colfax, Dept. 1108 Denver, CO. 80202

/S/ Mark E. Brennan
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