Free Proposed Voir Dire - District Court of Arizona - Arizona

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Terry Goddard Arizona Attorney General Michael E. Gottfried Assistant Attorney General State Bar No. 010623 1275 West Washington Street Phoenix, Arizona 85007-2997 Phone: (602) 542-7693 Fax: (602) 542-7670 E-mail: [email protected] Attorneys for Defendants IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA ALBERT W. DELEON, No. CV 04-0446 PHX JAT (JRI) Plaintiff, v. DORA B. SCHRIRO; et al., Defendants. Plaintiff, pro se, and Defendants Reyes, Avalos, Paredez, and Ramon, by undersigned counsel, hereby submit the parties' Joint Proposed Voir Dire. GENERAL 1. 2. 3. 4. 5. 6. Do you personally know or have you ever heard of any of the persons identified by the court as associated with this case. If your answer is "yes" please explain who you know, how you know them or came by that information. Do you have difficulty hearing or seeing? Is there anything that would make it impossible for you to attend the entire trial? Do you have any problems sitting or concentrating for long periods of time? Have you ever served as a juror before? JOINT PROPOSED VOIR DIRE

#87032 ­ Joint Proposed Voir Dire

Case 2:04-cv-00446-JAT

Document 268

Filed 11/26/2007

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7. 8. 9.

Were you the foreperson? Did you vote with the majority? Do you feel that you are the type of a person who would have difficulty refraining from making a decision in this case until you have heard all the evidence and deliberated with your fellow jurors? Do you feel you are the type of person who would have difficulty refraining from speculation in making a decision? EDUCATION

10.

11. 12. 13.

Have you or any family member or close friend ever worked in law enforcement? If your answer is "yes" please explain. Have you, any family member or close personal friend ever worked for the Arizona Department of Corrections? Do you, any family member or close friend currently work for any branch of government including national, state, or local? If your answer is "yes" please explain.

14.

Do you, or any close family member work for an insurance company or related business? If your answer is "yes" please explain.

15.

Do you have any legal or medical education and/or training? LITIGATION

16.

Have you, or any close friend or relative ever been involved in a civil lawsuit? As a plaintiff (person suing), or a defendant (person being sued)? If your answer is "yes" please explain.

17. 18. 19.

Has anyone ever made a claim against you for an injury? Have you or anyone in your family or close friend made a claim for injuries? Have you, or anyone in your family, or close friend, gone to a lawyer to explore pursuing a claim for injury?

#87032 ­ Joint Proposed Voir Dire

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BIAS Do you or any immediate family member have any strong feelings concerning the civil justice system or people who file or defend lawsuits? If your answer is "yes" please explain. Do you feel that a defendant in lawsuit must have done something wrong or they would not have been sued? If your answer is "yes" please explain.

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#87032 ­ Joint Proposed Voir Dire

22. 23. 24. 25.

Have you had any experience with governmental agencies, such as the State of Arizona, which would influence your ability to decide this case? Have you or anyone in your family, or close friend, ever made a claim or brought a lawsuit against any governmental entity? Do you feel that the State of Arizona or the Arizona Department of Corrections or its employees should be held to a greater or different standard than others? Do you have any difficulty with the proposition that a person bringing a lawsuit has the burden of proving their case and that the defense does not have to prove anything? Do you have any strong feelings about the State of Arizona that might affect your ability to sit as a fair and impartial juror in this case? Have you, a family member, or close personal friend, ever been charged or convicted of a felony? If so, who? What offense? Where? When?

26. 27.

28.

Have you, a family member, or close friend ever been incarcerated in jail or prison? If so, who? What offense? Where? When?

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Case 2:04-cv-00446-JAT

Document 268

Filed 11/26/2007

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#87032 ­ Joint Proposed Voir Dire

Copy mailed the same date to: Albert W. DeLeon, #P269470 MARICOPA COUNTY LOWER BUCKEYE JAIL 3250 West Lower Buckeye Road Phoenix, Arizona 85009 s/ C. Jordan Secretary to Michael E. Gottfried IDS04-0271/RSK:G03-03830

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