Cuevas v. Golden Gate Bridge, Highway & Transportation District
Filing
20
PRETRIAL ORDER (Beeler, Laurel) (Filed on 3/24/2017)
1
2
3
4
5
6
7
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
San Francisco Division
United States District Court
Northern District of California
11
NEPTALI CUEVAS,
13
14
15
Case No. 16-cv-07051-LB
Plaintiff ,
12
CASE-MANAGEMENT AND
PRETRIAL ORDER (JURY)
v.
GOLDEN GATE BRIDGE, HIGHWAY &
TRANSPORTATION DISTRICT,
Defendant .
16
17
The court held a case-management conference on March 16, 2017 and issues this case-
18
management and pretrial order.
19
I. GENERALLY APPLICABLE RULES
20
Parties must comply with the procedures in the Federal Rules of Civil Procedure, the local
21
rules, the general orders, Judge Beeler’s standing order, and the Northern District’s general
22
standing order for civil cases titled “Contents of Joint Case Management Statement.” Local rules,
23
general orders, general standing orders, and a summary of the general orders’ electronic filing
24
requirements (including the procedures for emailing proposed orders to chambers) are available at
25
http://www.cand.uscourts.gov (click “Rules” or “ECF-PACER”).
26
27
28
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
1
II. CASE-MANAGEMENT AND TRIAL DATES
2
All hearings will be held in Courtroom C, 15th Floor, U.S. District Court, 450 Golden Gate
3
Avenue, San Francisco, California. The following are the disclosure, filing, and hearing dates:
4
Case Event
Filing Date/Disclosure
Deadline/Hearing Date
Date to seek leave to add new parties or amend the pleadings
9/14/2017
Updated joint case-management-conference statement
7/23/2017
Further case-management conference
7/27/2017 at 11:00 a.m.
ADR completion date
7/20/2017
Non-expert discovery completion date
10/27/2017
11
Expert disclosures required by Federal Rules of Civil
Procedure
10/27/2017
12
Rebuttal expert disclosures
11/13/2017
13
Expert discovery completion date
12/28/2017
14
Last hearing date for dispositive motions and/or further casemanagement conference
12/14/2017 at 9:30 a.m.
Meet and confer re pretrial filings
1/8/2018
Pretrial filings due
1/25/2018
Oppositions, objections, exhibits, and depo designations due
2/1/2018
Final pretrial conference
2/22/2018 at 1:00 p.m.
Trial
3/5/2018 at 8:30 a.m.
Length of trial
5 days
5
6
7
8
9
United States District Court
Northern District of California
10
15
16
17
18
19
20
21
22
III. ALTERNATIVE DISPUTE RESOLUTION
23
The parties agree to participate in a settlement conference before Magistrate Judge Jacqueline
24
Scott Corley to occur by the date specified in the above chart if possible. The settlement judge will
25
contact the parties with a date and time for the settlement conference. The parties must notify the
26
court promptly if the case resolves.
27
IV. DISCOVERY PROCEDURES
28
A. The parties must comply with the procedures regarding discovery and discovery disputes
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
2
1
2
3
4
in Judge Beeler’s standing order.
B. Each side is limited to ten depositions and twenty-five interrogatories, as provided by
Federal Rules of Civil Procedure 30 and 33, absent a further court order.
C. If the ADR specified in the previous section is being conducted before the discovery cut-
5
off deadline, counsel must meet and confer in person or by telephone no later than 21 days before
6
the ADR and before preparing any exchanged or confidential settlement statements required by
7
the ADR process. The purpose of the meeting is to identify and exchange whatever discovery is
8
needed for all sides to evaluate the case for settlement. Counsel must cooperate in providing
9
discovery informally and expeditiously before ADR.
10
In addition, before the parties participate in the ADR specified in the previous section, each
United States District Court
Northern District of California
11
party is limited to three depositions each absent stipulation or a further order of the court.
12
V. MOTIONS
13
The parties must file any motions, oppositions, and reply briefs on the schedule set forth in
14
Civil L. R. 7. The parties also must follow all procedures in Judge Beeler’s standing order.
15
VI. PRETRIAL FILINGS AND PROCEDURES
16
The court’s procedures require the parties to confer in person to resolve disputes, reach
17
stipulations, avoid duplicate and cumulative exhibits and witnesses, and ensure an orderly trial.
18
The following sections address filing deadlines and the procedures that the parties must follow
19
when submitting their pretrial filings and exhibits.
20
A. 30 Days Before Final Pretrial Conference: Serve (But Not File) Motions In Limine.
21
Each motion must be in a separate memorandum entitled “[Party’s Name’s] Motion in Limine
22
[#] to Exclude [Subject],” be limited to circumstances requiring advance ruling, and be no longer
23
than seven pages absent leave of court. Usually five motions in limine are sufficient.
24
B. 23 Days Before Final Pretrial Conference: Serve (But Not File) Oppositions.
25
Each opposition must be in a separate memorandum entitled "[Parties Name’s] Opposition to
26
Motion in Limine [#] to Exclude [Subject]” and be no longer than seven pages absent leave of
27
court. There will be no replies.
28
C. 21 Days Before Final Pretrial Conference. The parties must file the following:
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
3
1
1. Motions in Limine. The moving party will collate and file each motion and opposition
2
back-to-back, which means there will be one paired set for each motion in limine on the docket.
3
2. Joint Proposed Pretrial Order (instead of a pretrial conference statement) with the
4
following:
5
(a) a brief description of the claims and defenses to be decided;
6
(b) a statement of the relief sought;
7
(c) all stipulated, undisputed facts;
8
(d) all disputed fact issues to be tried, organized by count and described with the same
9
specificity as any contested element in the jury instructions;
(e) each disputed legal issue with citations but without extended argument;
11
United States District Court
Northern District of California
10
(f) the parties’ stipulations;
12
(g) the parties’ estimates of total trial time; and
13
(h) the status of settlement negotiations and whether further negotiations might be productive.
14
The proposed order must specify which issues are for the court to decide instead of the jury.
15
3. Attachments to Be Appended to the Joint Proposed Order. The filing must be filed as
16
separate attachments to the joint proposed order:
17
(a) Signed Stipulations in a form that can be introduced as evidence at trial;
18
(b) Joint Exhibit List with columns for exhibit number, description and bates range, offered
19
into evidence, admitted into evidence, sponsoring witness, and limits on use (see below regarding
20
numbering and organization of exhibits); and
21
(c) Each party’s separate witness list for case-in-chief witnesses (including those appearing
22
by deposition) with a short summary of the testimony, specifying their non-cumulative testimony,
23
and an hour-and-minute time estimate per witness. Experts and witnesses not included in the
24
witness list may not be used in a party’s case-in-chief.
25
(d) Joint proposed verdict form or separate verdict forms if a joint form is not possible.
26
(e) Joint voir dire questions supplemented by any separate requests.
27
(f) Any proposed jury questionnaire that differs from the court’s standard questionnaire
28
appended at the end of this order.
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
4
4. Joint Jury Instructions (Disputed and Undisputed). The instructions must include a
2
table of contents, be arranged in a logical numerical sequence, and be supported by citations (with
3
pin cites) to the authority for the instruction (e.g., to the Ninth Circuit Model Jury Instructions, the
4
California Civil Jury Instructions, and/or case law). If undisputed, an instruction must be labeled
5
“Stipulated Instruction.” If disputed, the parties’ versions must bear the same instruction number,
6
be labeled with the sponsoring party’s name, and be inserted back to back in the logical place in
7
the overall sequence. If the opposing party does not have a counter instruction and instead
8
contends that no instruction should be given, the party should say so in a separate page inserted in
9
lieu of the alternate instruction. If the parties modify a form instruction, they must identify the
10
modification clearly and include the form instruction in the packet. If the parties agree to form
11
United States District Court
Northern District of California
1
preliminary instructions, general instructions, and concluding instructions, they may cite the
12
numbers of the instructions in the current version of the Ninth Circuit Manual of Model Civil Jury
13
Instructions (http://www.ce9.uscourts.gov) but do not need to include them in the packet. The
14
parties must include a short statement of the case to be read to the jury during voir dire as part of
15
the preliminary instructions.
16
17
5. Separate Memoranda on Disputed Jury Instructions. Each party must file a
memorandum of law — organized by instruction number — regarding disputed jury instructions.
18
6. Trial Briefs on any remaining issues.
19
7. Copies of Federal Rule of Civil Procedure 26(a)(3) Disclosures. By designating an
20
exhibit, a party generally waives any objection to it if offered by the other side absent clearly
21
available objections (such as objections under Rules 402 and 403 or admissions by party
22
opponents that would be inadmissible hearsay if offered by the party opponent).
23
8. Chambers Copies of These Materials. The chambers copies of these materials must be
24
submitted in a binder, labeled on the front and spine with the case name and “Trial Submissions,”
25
and have labeled tabs separating the filings to reflect the organization in this section. The court’s
26
standing order requires two chambers copies.
27
28
9. Word Versions Emailed To Chambers. In addition to e-filing and lodging paper copies
see Judge Beeler’s standing order, counsel must email the joint proposed order, the jury
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
5
1
2
3
4
instructions, and the verdict form in Word to lbpo@cand.uscourts.gov.
D. 14 Days Before Pretrial Conference. The parties must comply with the procedures in
sections E through G (below) and then lodge the following:
1. Lodge Joint Sets of Trial Exhibits with Deputy Clerk. The parties must prepare a joint,
5
single set of all trial exhibits. The exhibits must be in three-ring binders, and each exhibit must be
6
tagged and separated by a label divider identifying the exhibit number. Spine labels must identify
7
the exhibits in a particular binder. The exhibit binders must be marked “Original” and will be the
8
official record both at trial with the witnesses and on appeal. The parties also must lodge a second
9
copy of the exhibits labeled “Chambers Copy.” Lodge the exhibits with the deputy clerk, Roger
10
Moua. Include (and e-file) any updated exhibit list in each binder.
United States District Court
Northern District of California
11
2. Copies of Deposition Designations For Witnesses Appearing Only By Designation.
12
3. Copies of Designation of Interrogatories and Admissions.
13
4. Objections to Exhibits and Use of Depositions as set forth in Federal Rule of Civil
14
15
Procedure 26(a)(3)(B). Objections not raised are waived.
5. Chambers Copies. The chambers copies of these materials must be submitted in a binder,
16
labeled on the front and spine with the case name and a description of the contents, and have
17
labeled tabs separating the filings to reflect the organization in this section.
18
E. Other Procedures Regarding Exhibit Numbering and Organization.
19
1. Meet and Confer Regarding Exhibit Numbers. Before submitting exhibit lists and
20
binders, counsel must meet and confer to establish usable numbering conventions and eliminate
21
duplicate exhibits. Use numbers only, and if possible, exhibit numbers should be the same
22
numbers used in depositions. Otherwise, the deposition transcript must be conformed to the new
23
exhibit number to avoid jury confusion and to ensure that every exhibit has a unique number.
24
Blocks of numbers should be assigned to fit the needs of the case: e.g., Plaintiff has 1 to 99,
25
Defendant A has 100 to 199, Defendant B has 200 to 299, et cetera. All exhibits must be marked
26
“Trial Exhibit No.,” not Plaintiff’s Exhibit or Defendant’s Exhibit. A single exhibit must be
27
marked just once.
28
2. Exhibit Tags and Binders. The exhibit tag must be in the following form and must be
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
6
1
affixed on or near the lower right-hand corner if possible and on the back if it is not. Counsel must
2
fill in the tag but leave the last two spaces blank.
3
4
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
TRIAL EXHIBIT 100
5
Case No. ________________
6
Date Entered _____________
7
8
By______________________
Deputy Clerk
9
F. Deposition Designation For Witnesses Appearing By Deposition. These procedures
10
apply only to deposition designation for witnesses who appear by deposition and do not apply to
11
United States District Court
Northern District of California
reading depositions of live witnesses into the record while the witnesses are testifying.
12
1. Designating Counsel. To designate deposition testimony, counsel must photocopy the
13
cover page, the page where the witness is sworn, and each page with any proffered testimony
14
(with lines through testimony not proffered). Counsel must put lines through objections or
15
colloquy unless they are needed to understand the question. Any corrections (including
16
conforming exhibit numbers to trial exhibit numbers) must be done by hand. The finished packet
17
must be the script that allows smooth presentation of the witness, the oath, and the testimony. The
18
packet must be provided to the other parties at least 30 days before the pretrial conference. For
19
voluminous designations, the court requires advance notice by designating counsel because more
20
lead time is required. Counsel must be reasonable.
21
2. Reviewing Counsel. Reviewing parties must promptly review the packet and highlight in
22
yellow any passages objected to and write in the margin the legal basis for the objections. If a
23
completeness objection is made, the objecting party must insert the additional passages needed to
24
cure the completeness objection. A completeness objection generally should be made only if a few
25
extra lines will cure the problem. Such additions must be highlighted in blue, and an explanation
26
for the inclusion must be legibly handwritten in the margin. Counsel must line out any irrelevant
27
portions of the additional pages. Reviewing counsel must return the packets to the proffering party
28
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
7
1
2
3
to consider whether to accept the adjustments.
3. Counsel To Meet and Confer Regarding Adjustments. Counsel must meet and confer to
address reviewing counsel’s comments and any other issues.
4
4. Designating Counsel To Assemble Final Packet. Counsel for the proffering party must
5
collate and assemble a final packet that covers all remaining issues and provide it to the court 14
6
days before the pretrial conference (as set forth above). Any objections must be highlighted and
7
annotated as described in the preceding paragraphs. If exhibits are needed to resolve the
8
objections, designating counsel must include copies, with the relevant passages highlighted and
9
tagged. The court will read the packet and make its rulings in the margins in a distinctive manner.
10
5. Counter-Designations. The reviewing party must make any counter-designations by
United States District Court
Northern District of California
11
providing a packet with the counter-designated passages to the original designating counsel at the
12
same time as the reviewing party returns its objections to designating counsel. The original
13
designating counsel must supply any objections in the manner described in this section.
14
6. Video Depositions. The parties must follow the same procedures to facilitate ruling on
15
objections. The videos must omit dead time and objections and colloquy not necessary to
16
understand the answers.
17
G. Requests For Admissions And Interrogatories. Counsel must designate responses to
18
requests for admissions and interrogatory answers in the same manner and under the same
19
timetable as deposition designations.
20
VII. PRETRIAL CONFERENCE
21
22
23
24
25
Lead counsel for each party must attend.
VIII. PRETRIAL ARRANGEMENTS
A. Daily or Real-Time Reporting. Please make arrangements ten days before the trial date
with Debra Campbell, Supervisor of the Court Reporting Services, at 415-522-2079.
B. Electronic Presentation of Evidence. The court provides no equipment other than an
26
easel and a white board. If counsel will use electronic equipment such as computers, projectors,
27
and screens, the parties must share equipment to the extent possible. Extension cords must be
28
taped to the carpet for safety. The United States Marshal requires a court order to allow equipment
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
8
1
into the courthouse. Please work with Roger Moua (415-522-3140) on all courtroom layout issues.
2
IX. TRIAL AND TRIAL PROCEDURES
3
A. Schedule. The trial day is 8:30 a.m. to 1:30 p.m. (or slightly longer to finish a witness),
4
Monday through Friday, with one fifteen-minute break at 10:45 a.m. Counsel must arrive at 8:15
5
a.m. or earlier if any matters must be addressed outside of the jury’s presence.
6
7
8
9
10
B. Jury Selection. There are no alternate jurors in civil cases, and the jury will be selected as
follows.
The attached questionnaire will be given to the potential jurors, and copies of the responses
will be given to counsel at the beginning of voir dire.
The court’s jury selection procedures vary depending on the size of the ultimate jury.
United States District Court
Northern District of California
11
Assuming a final jury of 8 and 6 peremptory challenges, the court will call 18 to 20 jurors to fill
12
the jury box and a row in front of the bar. The jurors will be given numbers 1 through 18. The
13
remaining jurors will be seated in the public benches. The court will generally consider hardship
14
excuses at this point. The court then will question the 18 jurors and will allow counsel limited voir
15
dire. The court will address challenges for cause outside of the jurors’ presence, determine
16
whether to fill any empty seats, and if so, question the new jurors and consider any additional
17
challenges for cause. After a short recess, each side will exercise its peremptory challenges out of
18
the presence of the jurors. Of the remaining jurors, the eight (or other number of) jurors with the
19
lowest numbers will be the final jury.
20
The court will adjust the starting numbers depending on the number of jurors to be seated and
21
the number of peremptory challenges allowed. Also, the court may alter these procedures in its
22
discretion.
23
24
25
Once the jury is selected, the jurors’ names will be read, and they will be seated in the jury box
and sworn.
C. Jury Note Taking. Jurors may take notes. Note pads will be distributed at the beginning of
26
each trial and collected at the end of the day and locked in the jury room. The court will instruct
27
the jury on the use of notes in its preliminary and final jury instructions.
28
D. Time Limits. Ordinarily, the court sets time limits for opening statements, witness
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
9
1
examinations (direct, cross, or re-direct), and closing arguments at the final pretrial conference.
2
All of your examination time for all witnesses must fit within your witness time limits. The time
3
taken at a side bar or on objections will be charged to the examining party unless otherwise
4
ordered.
5
E. Opening Statements. Counsel must meet and confer about, and exchange, any visuals,
6
graphics, or exhibits to be used in the opening statements, allowing for time to work out objections
7
and any reasonable revisions. Opening statements begin after the jury is sworn and will be limited
8
to a predetermined time.
9
F. Advance Notice of Witness Order of Proof. By 2:00 p.m., counsel must give written
notice of the order of witnesses for the next court day and the exhibits (including merely
11
United States District Court
Northern District of California
10
illustrative exhibits) to be used on direct examination (other than for true impeachment of a
12
witness). The parties must notify the court by the end of the day of any objections to the exhibits,
13
and the court will schedule a conference that afternoon or the following morning to resolve the
14
dispute. The court encourages two days’ notice. If two days’ notice is given, then by 2:00 p.m. on
15
the calendar day immediately preceding the testimony, opposing counsel must provide any
16
objections to the exhibits and must provide a list of all exhibits to be used with the same witness
17
on cross-examination (other than for impeachment).
18
G. Witness Examinations. Generally there must be only one examining lawyer per witness
19
per party, and the examining lawyer must make any objections to the opposing counsel’s
20
examination. The parties must have witnesses ready to testify so that trial gaps are avoided. Gaps
21
may be construed as resting one’s case. In cases with multiple parties, counsel must coordinate
22
cross-examination to avoid duplication of testimony. When multiple parties are on one side, only
23
one counsel may cover a subject matter. Counsel must place copies of exhibits to be used by a
24
witness on the witness stand before the witness testifies.
25
Witnesses (except named parties) are excluded from the courtroom except when they are
26
testifying. If a testifying witness has not been excused before a recess, that witness must be seated
27
back on the stand when the court reconvenes. If a new witness is ready to be called immediately
28
after a recess, the witness must be in the first row after the recess.
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
10
1
2
3
The appropriate party or the court may read into the record the undisputed facts at appropriate
points in the trial.
H. Expert Testimony. Direct expert testimony is limited to matters disclosed in the expert’s
4
reports. Omitted material ordinarily may not be added on direct examination. Illustrative
5
animations, diagrams, charts, and models may be used on direct examination only if they were part
6
of the expert report, except that an expert may use simple drawings (such as those drawn by the
7
witness at trial) that plainly illustrate a report’s contents. If cross-examination fairly opens the
8
door, however, an expert may go beyond the written report on cross-examination and/or re-direct
9
examination. By written stipulation, all parties may relax these requirements. As to damages
studies, the cut-off for past damages is the date of the expert report (or an earlier date selected or
11
United States District Court
Northern District of California
10
used by the expert). Experts may project future damages after this cut-off date if they can meet
12
substantive standards for future damages. With timely leave of court or by written stipulation, the
13
experts may update their reports (or provide supplemental reports) to a date closer to the time of
14
trial.
15
I. Use of Depositions To Impeach A Trial Witness. The following procedures apply.
16
1. On the first day of trial, counsel must bring the original and clean copies of the depositions
17
to be used at trial. If counsel might use a deposition against a witness, counsel must provide the
18
court with a copy at the outset of the examination. Opposing counsel must have copies of witness
19
depositions immediately available.
20
2. Counsel must seek permission from the court before reading a passage into the record. For
21
example, counsel should state, “I wish to read page 210, lines 1 to 10, from the witness’s
22
deposition.” Counsel must pause briefly to allow any objection.
23
3. The first time counsel reads a deposition, counsel must state the deponent’s name, the name
24
of the lawyer asking the question, and whether the deposition was a Federal Rule of Civil
25
Procedure 30(b)(6) deposition. The first time a deposition is read, the court will instruct the jury
26
about depositions.
27
4. When reading the passage, counsel must employ the following technique. Counsel must
28
state, “question” and then read the question exactly, and then state, “answer” and read the answer
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
11
1
exactly. This will allow the jury and court reporter to follow who said what at the deposition.
2
Opposing counsel may ask to read additional testimony necessary to complete the context. It is not
3
necessary to ask, “didn't you say XYZ in your deposition” to lay a foundation.
4
J. Use of Depositions of Party-Deponents. Subject to Rule 403, a party’s depositions may be
5
used for “any purpose” and may be read into the record whether or not they contradict (and
6
regardless of who is on the stand). For example, a short party deposition excerpt may be used as
7
foundation for questions for a different witness on the stand.
8
9
K. Use of Depositions For Witnesses Appearing Only By Deposition. When the packet
(see above for procedures to assemble deposition packets) is read to the jury, the examiner must
read the questions (and any relevant colloquy) from the lectern while a colleague sits in the
11
United States District Court
Northern District of California
10
witness stand and reads the answers. While reading the deposition, the reader and “witness” must
12
refrain from undue emphasis or dramatization. If a read-in is short, a single attorney can read it all,
13
being careful to say “question” and “answer” for the court reporter’s and jury’s comprehension.
14
Exhibits may be projected onto the screen as they are referenced. Court reporters do not transcribe
15
video excerpts so counsel must file an exact copy of what was shown.
16
L. Exhibits. The parties must obtain prior permission from the court for jury notebooks. At
17
the end of each day, counsel must confer with each other and with the deputy clerk to confirm
18
what exhibits are in evidence and any limitations on their use. Counsel must bring any differences
19
to the court’s attention. Similarly, before closing argument, counsel must confer with each other
20
and the deputy clerk to finalize the exhibits and prepare any final exhibit list. That list may include
21
a brief non-argumentative description of the exhibit to help the jury access the exhibits.
22
23
M. Stipulations. Counsel must read all stipulations to the jury for them to be part of the
record.
24
N. Objections. Counsel must stand when making objections, give only the legal basis
25
(“objection, calls for speculation” or “objection, hearsay”), and refrain from making speeches.
26
O. Side Bar Conferences are discouraged. If matters must be discussed outside the jury’s
27
presence, counsel should raise them at the beginning or end of the day or while the jury is on
28
break.
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
12
1
CONFIDENTIAL
2
JUROR QUESTIONNAIRE
Please fill out this form as completely as possible and print clearly. Do not write on the back of
3
4
any page. Instead, if you need more room, use the space at the end. Thank you.
5
1.
2.
3.
4.
5.
6.
7.
6
7
8
9
10
United States District Court
Northern District of California
11
12
Your name:
Your age:
City in which you reside:
Your place of birth:
Do you rent or own your own home?
Are you married or do you have a domestic partner? ____Yes ____ No
Please list the occupation of your spouse or domestic partner.
8. If you are not married and do not have a domestic partner, are you (circle one, if applicable):
single
separated
divorced
widowed
9. If you have children, please list their ages and sex and, if they are employed, please give their
occupations.
13
14
15
16
10. What is your occupation and how long have you worked in it? (If you are retired, please
describe your main occupation when you were working).
17
18
19
20
21
11. Who is (or was) your employer?
12. How long have you worked for this employer?
13. Please describe your education background:
Highest grade completed:
College and/or vocational schools you have attended:
22
23
24
25
26
Major areas of study:
14. Have you ever had jury experience? ______ Number of times? ______
If yes: State/County Court ______ Federal Court ______
When?
Was it a civil or criminal case?
Did any of the juries reach a verdict? ______Yes ______No
27
28
CASE-MANAGEMENT AND PRETRIAL ORDER — No. 16-cv-07051-LB
14
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?