Schoolcraft v. The City Of New York et al
Filing
550
PROPOSED VOIR DIRE QUESTIONS. Document filed by Adrian Schoolcraft.(Smith, Nathaniel)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ADRIAN SCHOOLCRAFT,
Plaintiff,
10 Civ. 6005 (RWS)
-againstTHE CITY OF NEW YORK, et. al.,
Defendants.
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PLAINTIFF’S PROPOSED VOIR DIRE QUESTIONS
1.
Do any of you know any of the attorneys or parties, directly or indirectly?
2.
Please tell us about your work experience, beginning with who you work
for now and what your job is.
3.
Where are the other members of your immediate family employed?
4.
How many years of formal education do you have?
5.
Were you ever in the military?
a. What ranks did you hold?
b. What duties did you have?
c. Were you ever in the military police?
6.
Have any of you ever sued as a claimant in any injury case? [If prior
experience, details to be probed].
7.
Have any of you, or a family member, ever been sued by someone for any
reason?
8.
Have any of you, or a family member, or a friend ever been involved in
any type of incident involving medical malpractice? [If so, did any claim arise out of that
incident? Did you make a claim? Was a claim made against you? Was it resolved to your
satisfaction?]
9.
Do you have any opinions concerning medical malpractice in general,
whether favorable or unfavorable? What are these opinions?
10.
This is a case in which the plaintiff, a former police officer, has sued
Jamaica Hospital and some of its attending physicians. Would you have any difficulty being
completely fair and impartial in such a case? If so, please explain.
11.
Jamaica Hospital?
Are you or any member of your family or any friends employed by
12.
Have you or any member of your family or any friends ever been treated
at Jamaica Hospital?
13.
Have you or has any member of your immediate family ever held any job
in the medical field? If so, what was/is their position?
14.
Have any of your neighbors, friends or relatives ever held a job in (a) a
law enforcement agency, (b) any government agency, (d) the state or local police, (d) the FBI, (e)
any prosecutor's office, (f) probation or parole agency or (g) a private detective or security guard
agency?
a.
Did they ever talk to you about their job?
15.
Does your job cause you to work with any medical professionals or
hospitals?
16.
Are you or any member of your family or any friends employed by the,
State of New York, City of New York, the MTA, or the New York City Transit Authority or any
other municipal agency?
17.
Are you or any member of your family or any friends a prosecutor, police
officer, peace officer, corrections officer, or involved in traffic enforcement or any type of job
that involves public safety or law enforcement?
18.
Have any of you served as a juror at a trial before? If so, was it a civil or
criminal proceeding? Have you ever served as a jury foreperson? Have you ever served as a juror
on a grand jury?
19.
Have any of you had prior jury service in a civil case? Have any of you
had prior jury duty in a medical malpractice case? Have any of you had prior jury duty in a case
on which Law Enforcement officer was a party? Has that jury service given you any feelings
against either a party suing or person defending a lawsuit?
20.
Have you ever had to appear in court, or in any legal proceeding, for any
reason other than jury duty? If yes, please state when and explain why you appeared in court.
21.
Do any of you have any feelings about a person bringing a lawsuit?
22.
Do you have feelings or believe that lawsuits are not the proper way for
someone to seek compensation for damages they believe was caused by someone else?
23.
Do you have any feelings about medical malpractice lawsuits?
24.
malpractice case?
Do you know anyone who has ever sued or been sued in a medical
25.
Are you, or is any member of your family or any friend, a lawyer? If so,
what type of law is practiced?
26.
Are you, or is any member of your family or any friend, a doctor, a dentist
or medical professional? If so, what field of medicine is practiced?
27.
Has anyone read any articles or literature, or heard any discussions or
public speakers, concerning tort reform and the amounts of verdicts in civil cases? If so, have
you formed any opinions or ideas with reference to amounts of jury verdicts? Do you have any
opinions that, based upon what you may have heard in the media, there should be limit on the
amounts a plaintiff should be entitled to recover?
28.
In this case, two of the defendants are attending psychiatrists at Jamaica
Hospital. Do any of you feel a medical doctor is more worthy of belief than another member of
the public? Do any of you feel that a medical doctor is somehow more credible that another
member of the public?
29.
If a civilian and a medical doctor official give conflicting testimony about
the same incident, would you be inclined to believe the medical doctor over the civilian and
why?
30.
Do you know of any reason whatsoever why you could not sit in this case
and render an impartial verdict with full justice to all parties to the litigation?
31.
There has been a significant amount of coverage about this case in the
media. Have you or any member of your family or a close friend read or heard about this case in
the news?
a.
If so, have you formed an opinion about the facts in this case?
32.
Have you seen any video or heard anything on the radio or internet related
to Adrian Schoolcraft?
33.
Have you ever heard the name Adrian Schoolcraft prior to today?
34.
You may hear testimony in this case regarding “whistleblower” activity.
Do you have any opinion about whistleblowers? If so, what is that opinion?
35.
Do you have any religious or personal beliefs which prevent you from
awarding money damages for any reason?
36.
Will you keep an open mind until you have heard all of the evidence and
have received the charge as to the law applicable before making any determination concerning
this case?
Dated: New York, New York
October 23, 2015
By:
JON L. NORINSBERG (Norinsberg@aol.com)
Attorneys for Plaintiff
225 Broadway, Suite 2700
New York, N.Y. 10007
(212) 791-5396
TO:
All counsel for defendants.
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