Free Supplement - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 company? a. b. c. vs.

LAW OFFICES

BROENING OBERG WOODS & WILSON
PROFESSIONAL CORPORATION 1122 EAST JEFFERSON POST OFFICE BOX 20527 PHOENIX, ARIZONA 85036 (602) 271-7700

James R. Broening, #004036 William R. Phillips, #019949 Attorneys for Defendant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA JERRY SIMMS, a single man, Plaintiff, NO.CIV-03-1415 PHX ROS PROPOSED ADDITIONAL QUESTIONS FOR CONFIDENTIAL JUROR QUESTIONNAIRE

STATE FARM FIRE AND CASUALTY COMPANY, an Illinois corporation; ABC CORPORATIONS I-X; JOHN DOES IX, Defendants. Pursuant to direction of the court during the final Pretrial Conference of February 16, 2006, the parties propose the following additional questions for the Confidential Juror Questionnaire: A. 1. PLAINTIFF Have you or any family member ever been employed by any insurance

If yes, identify the insurance company. If yes, identify the person and the position that he/she held. If yes, could you fairly serve as a juror?

Case 2:03-cv-01415-ROS

Document 158

Filed 04/14/2006

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 wagering?

2.

Have you ever been insured by State Farm Fire & Casualty or State

Farm Mutual Automobile Insurance Company?

a. b. 3. a. 4.

If yes, please state with which carrier and for how long? If yes, could you fairly serve as a juror? How do you feel about "tort reform?" Do you feel the same about claims against insurers? Have any of you or any family ever represented an insurance company

as an attorney, accountant or agent? a. 5. If yes, please identify the person and his position. Have any of you had any occasion to read about of have contact with

Jerry Simms or Turf Paradise? a. b. If yes, please explain the nature and extent of your familiarity. Do you have strong beliefs about the business of horse racing/

B. 1.

DEFENDANT Have you or a family member ever testified as a witness, either at trial

or deposition, in a prior lawsuit? If so, please explain. 2. Have you or any family member been employed by or associated with an insurance company or insurance agency? 3. Have you or a family member ever had specific training in insurance,
2 Case 2:03-cv-01415-ROS Document 158 Filed 04/14/2006 Page 2 of 3

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construction or environmental science? 4. Have you or any member of your family made any insurance claim in recent years? a. b. c. case? If yes, what kind of claim? What did it involve? How would that experience impact you in serving as a juror in this

DATED this 14 day of April, 2006. BROENING OBERG WOODS & WILSON, P.C.

By s/ William R. Phillips James R. Broening William R. Phillips 1122 East Jefferson Post Office Box 20527 Phoenix, Arizona 85036 Attorneys for Defendant State Farm Fire and Casualty Company LAW OFFICE OF JOSEPH C. DOLAN

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3 Case 2:03-cv-01415-ROS Document 158 Filed 04/14/2006 Page 3 of 3
S:\BADFAITH\State Farm\Simms\Pleadings\Proposed Additional Questions for Confidential Juror Questionnaire.wpd

By s/ William R. Phillips for Joseph C. Dolan, Esq. 1650 North 1st Avenue Phoenix, Arizona 85003 Attorney for Plaintiff