Hoffman et al v. Ford Motor Company et al

Filing 232

ORDER. The Joint Motion For Juror Questionnaire 200 filed 02/06/2009 is granted in part by Judge Robert E. Blackburn on 03/10/2009. The attached juror questionnaire and concomitant cover sheet are approved for use in the trial of this case. On or before Thursday, 04/02/2009, counsel for the parties shall provide Joann Garcia, Jury Commissioner for the United States District Court for the District of Colorado, fifty (50) copies of the attached juror questionnaire and concomitant cover sheet by Judge Robert E. Blackburn on 03/10/2009. (Attachments: # 1 Cover Sheet to Juror Questionnaire, # 2 Juror Questionnaire)(sah, )

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00081-REB-CBS ERICA HOFFMAN, GARY HOFFMAN and SANDRA HOFFMAN, Individually, Plaintiffs, v. FORD MOTOR COMPANY, a Delaware corporation; TRW VEHICLE SAFETY SYSTEMS INC., a Delaware corporation, Defendants. JUROR QUESTIONNAIRE I.PERSONAL INFORMATION 1. Name:___________________________________ Mailing Address: Permanent Address (if different): ______________________________________________________ ______________________________________________________ ______________________________________________________ (City, State, Zip and County) (City, State, Zip and County) Rent or Own: ______ 2. 3. Age:___________ Gender (please circle): Date of Birth:__________________ Male Female II.EDUCATION TRAINING AND EXPERIENCE 4. Juror's Education: (please check most appropriate) _____ less than 6th grade degree _____ more than 6th grade but no high school degree _____ high school graduate 5. 6. _____ technical, business or two year _____ some college but no degree _____ four year college degree in _____ post graduate work or degree in Special Training or Skills: List any special training or skills you have: What is your current job status? (Please check most appropriate answer) _____ working full time _____ unemployed _____ working part time _____ retired _____ homemaker _____ full time student No______ 7. 8. Do you own your own business? Yes_____ Do you or anyone close to you have any employment, education, training or experience in the following areas? Yes No (a) Motor vehicle manufacturing or sales _____ _____ (b) Motor vehicle design or safety _____ _____ (c) Motor vehicle engineering _____ _____ (a) Motor vehicle accident investigation or reconstruction _____ _____ (e) Statistical analysis _____ _____ (f) Tire sales _____ _____ (g) Product research and development _____ _____ (h) Product testing _____ _____ (i) Product manufacturing _____ _____ (j) Product research, development or testing _____ _____ Some of the questions below refer to "any member of your family." This is intended to include your mother, father, sisters, brothers, children and spouse. 9. 10. Have you, or any member of your family, ever worked for an automobile manufacturer or distributor? Yes_____ No_____ Have you, or any member of your family, ever worked in designing any type of vehicle or component of any vehicle? Yes_____ No______ 2 If so, please describe the work. ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ________________________________________ 11. Have you ever had any type of engineering training? Yes_____ No______ If so, when and what type of training did you receive? ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ________________________________________ 12. 13. 14. 15. 16. Who is your present (or most recent) employer? What is your present (or most recent) job title? Describe the duties of your current (or most recent) job: If retired, disabled, or unemployed, indicate the date of your retirement or your latest employment: Have you ever served in the military? If yes, indicate the following: branch of service: rank at discharge: 17. Juror's marital status: _____ single, never married _____ single but previously married for ____ years _____ currently married, have been for ____ years 18. If currently married, provide the following information: Spouse's education: Spouse's present employment status: Spouse's present occupation and employer: 3 _____ widow/widower _____ other years of service: form of discharge: Other types of jobs your spouse has held: 19. If you have children, please give their ages, gender and occupations: ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ _____________________________________________ 20. Other than the military, have you or any member of your family been employed by the United States government or any state or local government? Yes_____ No______ If yes, who was so employed, when and where? 21. Have you, or any member of your family, ever worked for a law enforcement organization? Yes_____ No______ If yes, who was so employed, when and where? 22. What are your hobbies, special interests, recreational pastimes and other sparetime activities, including sports? ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________ Do you listen to talk radio? If so, which show(s)? 23. 24. What is/are your primary source(s) of news? _____ TV _____ Magazines _____ Newspaper _____ Other _____ Radio 25. What magazines and newspapers do you regularly read? ___________________________________________________________ ___________________________________________________________ 4 ___________________________________________________________ ___________________________________________________________ ______________ 26. Have you ever been a member of professional or job-related organization (including labor unions)? Yes_____ No______ If yes, identify the organization(s). ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________ 27. What social, political, civic, religious, and other organizations do you belong to or are you associated with? Have you, or any member of your family, ever suffered long-term or permanent disability? Yes_____ No______ 28. If yes, please explain. 29. Have you previously served on a jury? If so, what type of case was it? Was a verdict reached? What was the verdict? Did anything happen during your previous jury service which might affect your ability to make a decision if you are selected as a juror during this term of court? Yes_____ No______ Yes_____ No______ Civil _____ Criminal _____ Yes _____ No _____ If yes, please explain. 30. Have you ever been a witness in a civil or criminal trial? 5 Yes_____ No______ If yes, please explain. ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________ 31. Have you or anyone in your family ever worked for: A lawyer or law firm An insurance company The court system A large corporation A doctor, hospital or health care organization Yes ____ ____ ____ ____ ____ No Employer & Family Member ____ ____ ____ ____ ____ III.MOTOR VEHICLES 32. Have you ever owned any vehicles manufactured by Ford Motor Company? Yes_____ Make: Model: Year: 33. Were you satisfied with the vehicle? Yes_____ 34. No______ No______ Do you currently own any vehicles manufactured by Ford Motor Company? Yes_____ Make: Model: Year: No______ 35. In your opinion, does Ford Motor Company make vehicles which are generally less safe than those made by others? Yes_____ No _____ Don't Know _____ 6 36. Have you, or any member of your family, ever had significant problems with a Ford vehicle? Yes_____ No______ Please explain why and what the experience was with the vehicle. ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ IV.DRIVING AND ACCIDENTS 37. 38. Do you drive? Yes_____ No_____ Have you ever driven a commercial truck, have any professional driving experience or training or driven as a part of your job responsibility? Yes_____ No_____ If yes, please describe: 39. Have you, or any member of your family, ever been involved in a motor vehicle accident? Yes_____ No______ If yes, please describe the accident: ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 40. Have you ever lost control of a vehicle that you were driving? Yes If yes, please explain what caused loss of control: No 7 41. Have you, or any member of your family, ever been involved in a motor vehicle accident while the driver or passenger of a Ford vehicle? Yes_____ No_____ If yes, please describe the vehicle: ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 42. Have you ever experienced or personally witnessed the death or severe physical suffering of anyone close to you resulting from a motor vehicle accident? Yes_____ 43. No______ Have you, or anyone you know, been injured by a defective motor vehicle? Yes_____ No______ If yes, what happened? ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 44. Do you believe that a good driver can control a vehicle under almost any circumstances? Yes_____ 45. No______ Do you wear a seatbelt? Always ______ Never _____ Sometimes _________ 46. Have you or anyone close to you ever experienced a seatbelt coming unlatched unexpectedly in an accident or otherwise? Yes _____ No _____ 8 V.PRODUCT, DESIGN, SAFETY AND REGULATION 47. Place an "X" next to the statement that most closely represents your opinion about government regulations on automobile manufacturers? Too Strict _____ About Right _____ Not Strict Enough _____ No Opinion _____ 48. How thoroughly do you think car companies test their vehicles before selling them to the public? Minimum testing _____ Average testing _____ Maximum testing _____ No Opinion _____ 49. In a dispute between an individual and a corporation, would you favor the: corporation _______ individual _________ neither________ 50. Please indicate whether you agree or disagree with the following statements. ANSWER EACH PART (a) THROUGH (g) Agree a) Most large companies are run in an ethical and honest manner. Comments: b) Most car accidents are caused by human error. Comments: c) All too often people who cause their own problems will try to blame their problems on a corporation. Comments: d) When I hear that an individual has filed a lawsuit 9 (1)_____ (2)_____ Disagree (1)_____ (2)_____ (1)_____ (2)_____ against a corporation, I usually think the corporation deserves blame and the individual deserves compensation. (1)_____ (2)_____ Comments: e) Government regulators who are supposed to oversee corporations often put the good of the corporations above the good of the public. (1)_____ (2)_____ Comments: f) The government should provide free health care for all citizens. (1)_____ (2)_____ Comments: g) It would be difficult for me to deliver a jury verdict that meant an injured person would receive no money. Comments: VI.PRODUCTS AND PARTIES 51. When you purchase a vehicle, do you read written warnings or instructions provided with the vehicle? Yes_____ 52. No______ Never Purchased a Vehicle______ (1)_____ (2)_____ Have you, or any member of your family, ever been employed by Ford Motor Company, any Ford, Mercury or Lincoln dealer or had any special interest in these businesses? Yes_____ No______ 53. Have you, or any member of your family, had any business dealings with Ford Motor Company? Yes_____ No______ 10 If yes, please describe the nature of the dealings and whether you had a favorable or unfavorable experience. ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 54. How would you describe your feelings with regard to the government's bailout of the automotive manufacturers? ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ If you have an opinion about the government bailout, please describe how your opinion would affect you views about this case. ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ Do you, or does anyone close to you, prefer Ford Motor Company products over those of other vehicle manufacturers? Yes _____ No______ Do you know, or have you heard of, the Plaintiffs to this action: Erica Hoffman, Gary Hoffman, or Sandra Hoffman? Yes_____ 58. No_____ 55. 56. 57. Are you familiar with the Defendant TRW Vehicle Safety Systems Inc.? Yes_____ No______ If yes, please describe how you heard of TRW and what you know about the company: ________________________________________________________________ ______________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 11 59. Do you have a favorite NASCAR driver? If so, please state the auto manufacturer for which he/she drives. Yes_____ No_______ Manufacturer________________ VII.LAWSUITS 60. Have you, or a member of your family, ever been sued? Yes_____ No______ If yes, please describe: ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 61. Have you, or a member of your family, ever filed a lawsuit? Yes_____ No______ If yes, please describe: ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 62. Have you, or a member of your family, or anyone close to you ever sued Ford Motor Company? Yes_____ No______ If yes, identify the name of the individual who filed suit. ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 63. Have you, or a member of your family, ever filed a complaint against a law enforcement officer or agency? Yes_____ 64. No______ Have you, or a member of your family, ever been arrested or charged with a crime other than a traffic offense? 12 Yes_____ 65. No______ Do you believe that automobile manufacturers place a higher priority on company profit than on consumer safety? Yes_____ No______ 66. Are you concerned that jury verdicts against corporations cause a substantial increase in the price of products we buy? Yes _____ No _____ Maybe ______ 67. Have you or any member of your family or close friends ever worked for a company that has been sued? Yes_____ No______ If yes, please explain, including whether you thought the suits were fair or unfair: 68. Have you, or a member of your family, read in the newspapers or magazines, heard on the radio or seen on television anything concerning lawsuits, accidents, hearings, or safety issues involving Ford Motor Company? Yes_____ No______ If yes, please give a brief description: ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ 69. If you responded yes to No. 68, has the news you've heard or read about involving these Ford products affected your opinion of Ford such that you have already made a judgment and could not be a fair and impartial juror in this case? 13 Yes_____ 70. No______ Do you feel that it is wrong or inappropriate to file a lawsuit to settle a dispute? Yes_____ No______ If Yes, please explain. 71. Do you have negative feelings toward personal injury lawyers or plaintiff's lawyers? Yes_____ No______ If Yes, please explain. 72. Do you feel that a company should not be required to compensate individuals injured by the company's negligence or its defective products? Yes_____ 73. No______ Do you believe that corporations have been forced out of business because of the high cost of insurance or the fear of frivolous lawsuits? Yes_____ No______ If Yes, please explain. 74. If you find for the plaintiffs, do you feel that you could award money damages proved by the plaintiffs for mental and emotional suffering over and above the actual monetary damages suffered? Yes_____ No______ If No, please explain. 75. Do you feel there should be a cap or limit on the amount of damages any one plaintiff is awarded? Yes_____ No______ 14 76. Do you feel that lawyers who bring personal injury lawsuits on behalf of injured clients are generally untrustworthy? Yes_____ No______ 77. Have you ever been a member of an organization that supports tort reform or have you ever worked to oppose alleged frivolous lawsuits? Yes_____ No______ 78. Do you believe that it is wrong for people to bring lawsuits for personal injury damages? Yes_____ No______ 79. Do you believe that your insurance rates have gone up because of alleged lawsuit abuse? Yes_____ No______ VIII.HEALTHCARE AND SOCIAL ASSISTANCE 80. Do you believe that a parent or guardian should obtain necessary medical treatment for a child or dependent regardless of the cost of the treatment? Yes _____ ***** I declare that the above information is true to the best of my knowledge. I know that if I have willfully misrepresented a material fact on this questionnaire, I may be guilty of and punished under federal law for perjury or making a false statement. Dated: ______________________________ No _____ No opinion _____ Signed:____________________________________________ Print Name: ________________________________________ 15

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