Free Proposed Voir Dire - District Court of Colorado - Colorado

Case 1:03-cv-02451-PSF-CBS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Phillip S. Figa

Civil Action No. 03-F-02451-PSF-CBS

BRYCE E. CARLEY, Plaintiffs, v. UNION PACIFIC RAILROAD COMPANY, a corporation, Defendant.

DEFENDANT'S PROPOSED VOIR DIRE

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Union Pacific is a fairly big company. Do you have any feelings, good or bad, about big companies? Because the Union Pacific is a big company, you may have some prejudice or bias against the Union Pacific. Does anyone have a prejudice or bias against the Union Pacific? You will be instructed at the end of the case that Mr. Carley and the Union Pacific stand equal before the law. Will you be able to treat Mr. Carley and Union Pacific as equals before the law? Have you ever had any negative experiences with a railroad, such as waiting too long at a crossing for a train to go by, or going over a rough crossing? In this case you, the jury, will determine what, if any, damages to award Mr. Carley. Does anyone here believe that the purpose of the damage award is to make the plaintiff wealthy or well off?

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Does anyone here believe that the purpose of the damages award in this case is to punish the Union Pacific for something they either did or failed to do? Has anyone on the jury panel ever thought to themselves that juries in general award too much money to people when they get hurt and bring a lawsuit? Has anyone on the jury panel ever thought to themselves that juries in general don't award enough to people when they get hurt and bring a lawsuit? Has anyone on the jury panel ever thought that injured people are sometimes awarded large verdicts that they don't deserve? Why do you think that happens? Who do you believe is responsible for these large verdicts? Has anyone on the jury panel ever had a shoulder injury? Please describe this shoulder injury. Has anyone on the jury panel ever been in an accident where they were injured? Please describe this accident. Please describe the injury? Has anyone ever filed a Workers' Compensation claim? Please describe the Compensation claim. Please describe the injury. Has anyone ever filed a lawsuit for injuries they sustained in an accident? Please describe the personal injury you sustained and the circumstances surrounding the accident. What was the outcome of the lawsuit? circumstances surrounding this Workers'

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Has anyone ever been on a jury? Was it a civil or criminal case? What was the jury verdict? Do you believe that the Government has an obligation to provide food and shelter to the homeless. Do you believe that the Government should provide health care for all citizens. Do you believe that all companies should be required to provide a full fringe benefit package to its employees including health care and paid vacations.

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DATED this 2nd day of September, 2005. Respectfully submitted,

_s/Mark C. Hansen_______ MARK C. HANSEN Union Pacific Railroad Company 1331 17TH Street, Suite 406 Denver, CO 80202 (303) 964-4583 FAX: (303) 964-4585

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CERTIFICATE OF SERVICE I hereby certify that on this 2nd day of September, 2005, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected] Sabina Y. Chung, Esq. Jack D. Robinson, Esq. SPIES, POWERS & ROBINSON, P.C. 1660 Lincoln Street, Suite 2220 Denver, CO 80264 Fredric A. Bremseth, Esq. Thomas W. Geng, Esq. BREMSETH LAW FIRM 810 East Lake Street Wayzata, MN 55391

[email protected]

I certify that there are no non CM/ECF participants in this case.

_s/Mark C. Hansen_______ MARK C. HANSEN Union Pacific Railroad Company 1331 17TH Street, Suite 406 Denver, CO 80202 [email protected]

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