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 Civil Action No. 04-cv-01067-REB-CBS WILLIAM R. CADORNA, Plaintiff, v. THE CITY AND COUNTY OF DENVER, COLORADO, a Municipal Corporation, Defendant. DENVER'S PROPOSED VOIR DIRE QUESTIONS Defendant, the City and County of Denver (hereafter "Denver"), by and through its attorneys, Jack M. Wesoky and Christopher M.A. Lujan, Assistant City Attorneys, submit the following proposed voir dire questions: 1. Do you or any member of your family or friend, have the responsibility on

the job for hiring, firing or discipline? 2. 3. In your work, do you have management or supervisory responsibilities? Have you had management or supervisory duties or the responsibility on

the job for hiring, firing or discipline in the past? 4. 5. 6. study? What other occupations have you worked in? Have you ever been fired from a job? When? Where? What is your educational background? What was your major area of

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7.

Have you ever been involved in any lawsuit either as a party or in some

other capacity, such as a witness? If so, please explain. 8. Has any member of your family or friend or acquaintance been involved in

any lawsuit either as a party or in some other capacity, such as a witness? If so, please explain. 9. 10. Have you ever served on a jury previously? If so, please explain. Have you ever filed any complaint or grievance against an employer? If

so, please explain. 11. Have you or any member of your family, or close friend or acquaintance

ever filed a complaint of discrimination against an employer? If so, please explain. 12. Do you believe that you have ever been discriminated against on the basis

of age? If so, please explain. 13. Has anyone in your family been discriminated against on the basis of age?

If so, please explain. 14. Has anyone in your family worked for the City and County of Denver at

anytime? If so, please explain. 15. Has anyone in your family worked as a Firefighter for the Denver Fire

Department or any other fire department? If so, please explain. 16. Have you had any interactions with the City of Denver, or heard or read

anything about the City that has caused you to form any opinions, good or bad, about City government or its employees? Please explain.

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17.

Have you had any interactions with the Denver Fire Department, or heard

or read anything about the Denver Fire Department that has caused you to form any opinions, good or bad, about the Denver Fire Department or its employees? Please explain. 18. What are your reactions to an employer firing an employee who was

caught stealing while on duty after conducting an investigation and after giving the employee an opportunity to present his side of the story? Please explain. 19. employee? 20. 21. Is it possible to be both fair and still make a wrong decision? Do you think it is wrong for an employer not to reinstate an employee that What steps do you think a public employer needs to take before it fires an

has retired? Please explain. 22. 23. Please explain what the word "voluntary" means to you. Can you follow a jury instruction that you personally disagree with?

Please explain. 24. If after evaluating the evidence and reading the jury instructions, can you

render a decision in favor of Denver even if you personally disagree with the decisions that were made? 25. Do you know any attorneys? If so, what area of law do they practice in?

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Respectfully submitted this 12th day of June, 2006. JACK M. WESOKY Assistant City Attorney CHRISTOPHER M.A. LUJAN Assistant City Attorney By: s/ Christopher M.A. Lujan______ Christopher M.A. Lujan Assistant City Attorney 201 W. Colfax Ave., Dept. 1108 Denver, CO 80202 Telephone: 720-913-3100 Facsimile: 720-913-3190 [email protected]

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CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on June 12, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: Mark E. Brennan [email protected] s/ Marilyn Barela Marilyn Barela, Legal Secretary Office of the Denver City Attorney

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