EXHIBIT "A"
Case 2:04-cv-00347-FJM Document 150-2 Filed 03/01/2006 Page 1 of 3
CMS, LOPEZ-MORENO, CARRASCO & CORNWELL'S PROPOSED VOIR DIRE QUESTIONS
1. Have you or any close personal friend, relative or family member ever worked for A. Correctional Services Corporation? B. Correctional Medical Services? C. State of Arizona? D. County of Maricopa? E. Northland Insurance Company? F. PHICO Insurance Company? 2. Are any of you familiar with one of the underlying cases/claims involving Mr. Jose Valdez? 3. Are any of you familiar with another of the underlying cases/claims involving Mr. Blas Casa Perez, III? 4. Have you or any close personal friend, relative or family member ever worked in a A. Correctional institution? B. Law enforcement? C. The police or sheriff offices? D. Private investigations? E. Legal field? F. Public Defender's office? G. Prosecutor's office? 5. Have you or any close personal friend, relative or family member ever been incarcerated for any reason? A. If so, did you seek medical attention while incarcerated? B. Or, if so, did your close personal friend, relative or family member seek medical attention while incarcerated? 6. 7. Have any of you ever had a heart condition? Have any of you ever had a heart attack?
Case 2:04-cv-00347-FJM
Document 150-2
Filed 03/01/2006
Page 2 of 3
8. Have you or any close personal friend, relative or family member worked in the healthcare profession, (Nurse, LPN, RN, Physician, Physical Therapist or Occupational Therapist)? 9. Have any of you ever brought a breach-of-contract or fraud claim against a party? 10. Have any of you ever been a defendant in a lawsuit claiming breach-ofcontract or fraud? 11. Has anyone been an insured by an insurer that went bankrupt, or know of someone who has? 12. Have any of you had to pay for your own defense because your insurer went bankrupt? 13. Have any of you had to defend yourselves because an insurer refused to defend?
Case 2:04-cv-00347-FJM
Document 150-2
Filed 03/01/2006
Page 3 of 3