Rosario v. City of New York et al

Filing 378

ORDER: It is hereby ORDERED that by May 25, 2022, the parties shall jointly file a proposed juror questionnaire, prepared with reference to the previously approved voir dire questions and a sample from a recent civil trial, which are attached hereto. The parties should indicate any disagreement through footnotes or highlighted text. (Signed by Judge Lorna G. Schofield on 5/18/2022) (mml)

Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 1 of 17

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------------------------------X
:
RICHARD ROSARIO,
:
Plaintiff,
:
:
-against:
:
CITY OF NEW YORK, et al.,
:
Defendants. :
:
-------------------------------------------------------------X

18 Civ. 4023 (LGS)
ORDER

LORNA G. SCHOFIELD, District Judge:
WHEREAS, the jury trial in this case is scheduled to begin on July 25, 2022, at 9:45 a.m.
WHEREAS, the Court has determined that under the circumstances, including the current
state of the COVID-19 pandemic, a juror questionnaire will be used in aid of voir dire. It is
hereby
ORDERED that by May 25, 2022, the parties shall jointly file a proposed juror
questionnaire, prepared with reference to the previously approved voir dire questions and a
sample from a recent civil trial, which are attached hereto. The parties should indicate any
disagreement through footnotes or highlighted text.
Dated: May 18, 2022
New York, New York

Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 2 of 17
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VOIR DIRE EXCERPT
Richard Rosario v. The City of New York, et al.,
18 Civ. 4023
V.

OUTLINE OF THE CASE
As I mentioned before, this is a civil case.
You may hear the term “plaintiff” and “defendant.” In this case, the plaintiff is Richard

Rosario, a private citizen. The defendants are Charles Cruger, Richard Martinez and Gary
Whitaker, who were police officers with the New York City Police Department. The City of
New York is also a defendant. The term “plaintiff” just means the party who brought the
lawsuit, and “defendant” means the person who was sued. You must not attach any significance
to the terms “plaintiff” and “defendant” in weighing the evidence. I’m going to refer to each
party to this lawsuit by just their last name. I don’t mean them any disrespect by doing that. It
will just take less time and paper.
Richard Rosario was arrested on July 1, 1996, for the Bronx murder of Jorge Collazo. In
1998, a jury convicted Rosario of the murder and he was sentenced to prison. In 2016, after
nearly twenty years in custody, Rosario’s conviction was vacated, and he was freed from prison.
In this lawsuit, Rosario claims that the Defendants violated his constitutional rights and caused
him to be wrongly prosecuted for murder. Each of the Defendants deny any wrongdoing and
assert that they acted properly in arresting and prosecuting Rosario. This is just a summary of
the parties’ claims and defenses.
Under the law, the facts are for the jury to determine and the law is for the Court. The
two areas are separate and distinct. At the beginning of the case and again at the end of the case,
I will instruct you on the law, and you are required to accept the law as I explain it to you. It will

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be your job to determine the facts under my explanation of the law.

VI.

INTRODUCTORY QUESTIONS ABOUT THE CASE
Those of you who were not chosen as part of the sixteen, please make a note if you would

answer yes to any of these questions so that if you are called up later, you can tell me about it.
First, let me ask some very general questions.
1.

Is there anyone who before today has heard or read about this lawsuit or the events
leading up to it? Is there anyone who believes that he or she cannot be fair and impartial
in a case involving these allegations?

2.

Is there anyone who believes that he or she cannot be fair and impartial in a case
involving Richard Rosario, Gary Whitaker, Irwin Silverman, Charles Cruger, Joseph
Fortunato, Richard Martinez, Edward Monks and the City of New York?

3.

Is there anyone who believes that he or she will not be able to apply the law as I explain
it, including about how much – if any – money any party may recover, even if they
disagree with it?

4.

Do any of you have any physical or personal problems that would prevent you from
serving in this case, which is expected to last a little less than two weeks?

5.

Do any of you have any difficulty with your sight or hearing that could affect your
perception of the proceedings?

6.

Are you taking any medication that would prevent you from giving your full attention to
all the evidence?

7.

Does any juror have any difficulty in reading or understanding English?

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8.

Does anyone NOT live in Manhattan, the Bronx, or one of the following counties:
Westchester, Rockland, Putnam, Orange, Dutchess or Sullivan? [All in SDNY]. Does
anyone live in Queens? Brooklyn? Staten Island? [Not SDNY].

VII.

CASE SPECIFIC AND OTHER FOR CAUSE QUESTIONS
Now I will ask some questions that are more about this case.

1.

Have you or has anyone close to you ever been employed by a local, state, or federal
government agency?

2.

Have you or has anyone close to you ever been employed by a New York City agency or
any other city agency such as the department of corrections, police department, fire
department, or sanitation department? Is there anything about your employment with that
agency that would affect your ability to be fair and impartial in this case?

3.

Do you or does anyone close to you work in law enforcement?

4.

Have you or has anyone close to you ever attended any protests or demonstrations related
to police activity, whether for or against? Is there anything about that experience that
would affect your ability to be fair and impartial in this case?

5.

Have you or has anyone close to you ever been the victim of or eyewitness to a violent
crime? [Speak to juror privately]

6.

Have you or has anyone close to you ever had an interaction with a law enforcement
officer that would affect your ability to be fair and impartial in this case? [Speak to juror
privately]

7.

Have you or has anyone close to you ever been detained in a jail, prison, or other
correctional facility? [Speak to juror privately]

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8.

Have you or has anyone close to you ever been charged for a crime you or they did not
commit? [Speak to juror privately]

9. Do you believe that a police officer is more likely to tell the truth simply because he or she is
a police officer?
10. Would you tend to give more or less weight to the testimony of a witness who is a law
enforcement officer or prosecutor than other witnesses?
11.

Have you or has anyone close to you ever been a party to a lawsuit?

12.

Have you ever served on a grand jury? Where? When?

13.

Have you ever served on a trial jury? If so, was it civil or criminal? Did the jury reach a
verdict? (Do not tell us what the verdict was.)

14.

Do you or does anyone close to you have legal training? If so, would this prevent you
from applying the law as I instruct you? Will each of you (the entire venire) accept my
instruction that you are not to discuss the case with anyone, including attorneys you may
know, until you are excused as jurors?

VIII. INTRODUCTION TO THE PARTIES AND COUNSEL
1.

I’m going to ask each person to stand and briefly remove your mask as you are
introduced. The Plaintiff is Richard Rosario. Do you know, or have you had any
dealings with him?

2.

Mr. Rosario is represented by attorneys Nick Brustin, Emma Freudenberger, Anna
Hoffman, and Katherine Haas from the firm Neufeld Scheck & Brustin, LLP. Do any of
you know any of them or have you had any dealings with them or their firms?

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3.

The Defendants are Gary Whitaker, Richard Martinez, Charles Cruger and the City of
New York. Do you know, or have you had any dealings with them?

4.

The Defendants are represented by Brachah Goykadosh from the New York City Law
Department. Do you know [him/her] or have you had any dealings with [him/her] or the
New York City Law Department?

5.

Have any of you or anyone close to you ever been employed by or applied for
employment with these law firms or the New York City Law Department?

6.

Have you or has anyone close to you ever had a dispute with these parties or their
lawyers?

7.

Do you know any of the other potential jurors?
Do you know me or any of my staff?

IX.

WITNESS INTRODUCTION
I will now read you the names of potential witnesses and other people who may be

mentioned during the trial. My including a name, however, imposes no obligation on any party
to call that person as a witness. Some of these individuals might not testify. My question is
whether you personally know or have had any dealings with the following people (or places):

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1. Bhushan Agharkar, M.D., D.F.A.P.A.
2. Charles Cruger
3. Robert Davis
4. Jennifer Dysart, Ph.D.
5. Steven Fayer, M.D.
6. Detective Joseph Fortunato
7. Alexis Gonzalez
8. Assistant District Attorney David Greenfield
9. Joyce Hartsfield
10. Patrick Hoffman
11. Steven Kaiser
12. Lymari Leon
13. Carl Loewenson, Jr.
14. Carlos Maldonado, Jr.
15. Richard Martinez
16. Vivene Martinez
17. Detective Edward Monks
18. DeAnsin Parker, Ph.D
19. Jeanne Petrauskas
20. Assistant District Attorney Jeanne Petrauskas
21. Richard Rosario
22. Minerva Rosario
23. Chenoa Ruiz
24. Michael Sanchez
25. Michael Serrano
26. Irwin Silverman
27. Dan Slepian
28. Fernando Torres
29. Jenine Torres
30. John Torres
31. Nicole Torres
32. Detective John Wall
33. Gary Whitaker

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Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 8 of 17
Juror ID: _______________

PRELIMINARY INSTRUCTIONS
The purpose of this questionnaire is to provide information to the Court and the attorneys in this case, so that
they can determine whether you can be a fair and impartial juror. Please read the following instructions
carefully before completing any portion of this questionnaire. Please print your juror number in the space
provided at the top of each page.
YOU ARE SWORN TO GIVE TRUE AND COMPLETE ANSWERS TO ALL QUESTIONS IN THIS QUESTIONNAIRE. The
questions are not intended to inquire unnecessarily into personal matters. Although some of the questions may
appear to be of a personal nature, please understand that the Court and the parties must learn enough
information about each juror’s background and experiences to select a fair and impartial jury.
Please answer every question. If you do not understand a particular question or do not know the answer,
please write either “I do not understand” or “I do not know.” If you feel a question does not apply to you write
“N/A.” Please answer each question fully. Some questions have more than one part. There are no “right” or
“wrong” answers, only truthful answers. Remember, you are sworn to give true and complete answers to all
questions.
If you need extra space for any answer, please use the blank sheets of paper included at the end of the
questionnaire. Be sure to indicate on the blank page the number of the question you are answering. Do not
write anything on the back of any page.
If you believe that any of your answers contain private information that could embarrass you or otherwise
seriously compromise your privacy and wish to request that the Court keep them confidential and not distribute
them beyond the judge and the attorneys in the case, you may indicate that on one of the blank pages at the end
of this form. (Please identify the specific answer or answers that you believe should remain confidential.) After a
jury has been selected, all copies of your responses to the questionnaire will be destroyed, except one copy which
the judge will keep.
DO NOT DISCUSS YOUR QUESTIONS AND ANSWERS OR THE CASE WITH ANYONE, NOW OR UNTIL FURTHER
INSTRUCTED BY THE COURT. You should not discuss the questions or answers with fellow jurors. It is very
important that your answers be your own individual answers. More broadly, do not discuss the case with
anyone, including the lawyers, your fellow jurors, your family, your friends, or anyone else. Do not
communicate about the case in any way, including by text, telephone, e-mail, or social media (like Facebook
or Twitter). You must also avoid reading or hearing about the case (or anyone participating in the case) in
newspapers, in magazines, on the radio or television, or on the Internet.
DO NOT READ, WATCH, OR LISTEN TO ANY INFORMATION ABOUT THIS CASE OR CONDUCT YOUR OWN
RESEARCH ON THE CASE. Do not conduct any research into the case (or anyone participating in the case) at
any time before your entire jury service has been completed. That includes performing Internet searches,
asking other people about the case, reading news stories, books, or reports about the case, or watching films
or television programs that relate to the case.

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Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 9 of 17
Juror ID: _______________

SUMMARY OF THE CASE
The Court is selecting a jury for an approximately four-week trial beginning April 22, 2022. The trial
should end by around Friday, May 20, but may last a few days less or more. We generally will not sit on
Fridays.
This is a civil antitrust case brought by Plaintiff US Airways, Inc. against three defendants (collectively
“Sabre”). U.S. Airways is an airline. Sabre operates a computerized service for certain travel agents to, among
other things, book airline tickets.
US Airways contends that Sabre harmed competition and engaged in unlawful monopolization in
violation of the federal antitrust laws through certain exclusionary actions. Sabre disputes this contention and
denies that it harmed competition, engaged in unlawful monopolization, or committed exclusionary actions.]

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Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 10 of 17
Juror ID: _______________

1. Name: ________________________________________________________________________________________
First

Middle/Maiden

Last

2. What borough or county do you live in? _____________________
Do you live in Queens, Brooklyn or Staten Island?

Yes

No

3. What is your age?
4. What is your current employment status? (Please check all that apply)
 Employed Full-time  Employed Part-time  Homemaker
 Student

 Disabled

 Retired

 Looking for work (for how long? __________)

 Self-employed

 Unemployed (for how long?__________)

5. What is your current occupation? (If you are retired, unemployed, looking for work, or a homemaker, please
describe the last job you held outside the home)
Employer:
Job title:

How long you have you held this position:

Job duties/responsibilities:
6. List other jobs you have held in the past 5 years, including self-employment, beginning with the most recent. Please
also briefly describe the job duties you had, including whether you were a supervisor.
Employer

Approx. Dates
of
Employment

Jobs Held

Duties

7. What level of school did you reach?
 Less than high school  High school graduate

 Some college

 Trade school

 Associates Degree

 Post-grad/Masters

 Ph.D./M.D./Ed.D./J.D.

Degrees:

 College graduate

Major areas of study:

3

Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 11 of 17
Juror ID: _______________

8. Who lives with you? (Please check all that apply):
 Spouse or Domestic Partner  Child or Children ages: __________  Roommate(s)  Live Alone
9. What kind of work do the members of your household do; or if retired, what did they do? ___________________
10. Have you ever owned or operated a business?  Yes  No
If YES, please describe:
Years of operation:
If the business is not still operating, what is the reason?
11. Have you ever worked in a job that paid commission?

 Yes

 No

12. Do you, a family member, or anyone close to you have experience, education, or training involving any of the
following?
Contracts
 Self
 Family member
 Someone close
 No
(drafting, negotiating, reviewing)
Law
 Self
 Family member
 Someone close
 No
Marketing
 Self
 Family member
 Someone close
 No
Sales
 Self
 Family member
 Someone close
 No
Information Technology
 Self
 Family member
 Someone close
 No
Computer Programming
 Self
 Family member
 Someone close
 No
Websites
 Self
 Family member
 Someone close
 No
Hospitality
 Self
 Family member
 Someone close
 No
Airlines/Air Travel
 Self
 Family member
 Someone close
 No
Negotiations
 Self
 Family member
 Someone close
 No
Accounting
 Self
 Family member
 Someone close
 No
Broker
 Self
 Family member
 Someone close
 No
If YES, please identify the person and explain:
Please describe the training or experience in any areas checked above for you, a family member, or someone close
to you:
________________________________

13. Have you, a family member, or anyone close to you ever been employed by any of the following (check all that
apply)? If YES, please explain below.
Airline

 Self

 Family member

 Someone close

 No

Traditional travel agent/agency
(e.g., American Express)

 Self

 Family member

 Someone close

 No

Online booking site
(e.g., Expedia, Orbitz, Priceline)

 Self

 Family member

 Someone close

 No

Other internet travel site

 Self

 Family member

 Someone close

 No

American Airlines, America West

 Self

 Family member

 Someone close

 No

US Airways

 Self

 Family member

 Someone close

 No

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Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 12 of 17
Juror ID: _______________

Sabre

 Self

 Family member

 Someone close

 No

Travelport, Worldspan, Galileo

 Self

 Family member

 Someone close

 No

Amadeus

 Self

 Family member

 Someone close

 No

Travel industry

 Self

 Family member

 Someone close

 No

Government agency regulating airlines

 Self

 Family member

 Someone close

 No

If YES, please identify the person and explain:
How many years of employment:

Name of employer:

If YES for a second person, please identify the person and explain:
How many years of employment:

Name of employer:

14. Have you, a family member, or anyone close to you ever had business dealings with America West, US Airways, or
American Airlines?  Yes, I have

 Yes, a family member has

 Yes, someone close has

 No

If YES, please identify the person, which company and explain:

15. Have you ever flown on US Airways?  Yes
Were your experiences generally:  Positive

 No
 Neutral

 Negative

16. Have you heard of a company called Sabre, a technology company that provides software and services to travel
agencies, airlines and other travel-related businesses?  Yes  No
If YES, please explain what you heard:
17. Have you, a family member, or anyone close to you ever had business dealings with Sabre?
 Yes, I have

 Yes, a family member has

 Yes, someone close has

 No

If YES, please identify the person and explain:
18. Do you directly own, or have you ever directly owned, stock in US Airways, American Airlines, or Sabre?
 Yes

 No

If YES, which one(s):
19. How often did you fly on a commercial airplane before the 2020 pandemic?
 Very often

 Often

 Sometimes

20. Was your flying:  Mostly business

 Rarely

 Mostly pleasure

 Never
 Both equally

21. How satisfied have you been with your experiences flying during the pandemic?
 Satisfied

 Neutral

 Unsatisfied

 Have not flown

22. Which do you use to make airline reservations when you fly (Check all that apply)?
 Travel search sites (e.g., Expedia, Travelocity, Kayak). If YES, which one(s):
 Airline websites
 Airline telephone reservations
 American Express Travel
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Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 13 of 17
Juror ID: _______________
 Local travel agent/agency
 Cruise or tour company
 My company’s travel agent
 Other (please specify: ________________________)

23. Do you have one preferred airline?

 Yes

 No

 Not really, I fly many airlines

If YES, what airline?
24. Which of the following do you think typically has the lowest ticket price?
 Airline websites

 Online travel websites

 Other: ________________

 Unsure

25. What are the most important travel options that you consider when you are booking your own reservations? (e.g.,
which airline, flight times, seating, prices, etc.)

26. What social, civic, professional, labor (including unions), religious, or other organizations do you participate in?

27. Are you a leader in any of these organizations?  Yes

 No

28. Please name where you get your news, i.e., the name of the newspapers, magazines, websites or news apps:
_______________________________________________________________________________________
29. What topics do you enjoy reading about in newspapers, books, or magazines? _______________________________
_______________________________________________________________________________________________
30. What sort of things do you do in your spare time? ______________________________________________________
_______________________________________________________________________________________________
31. Have you or a member of your household ever been involved in a lawsuit or claim? (Check all that apply)
 Yes, filed lawsuit

 Yes, been sued

 No

 Yes, given a deposition and/or testified in court
If YES: Please explain who was involved, the circumstances, and how the lawsuit or claim was resolved:
____________________

Did anything happen during the lawsuit or claim that might affect your ability to be fair and impartial in this case? 
Yes  No
If YES, please explain: ____________________
_______________________________________________________________________________________________
32. Have you ever served on a jury?  Yes  No

If YES, how many times?

If YES, did anything happen during jury service that might affect your ability to be fair and impartial in this case?
 Yes  No

If YES, please explain: ____________________
_______________________________________________________________________________________________
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Juror ID: _______________

Please describe each case:
Civil or
Criminal

Type of Case
(e.g. personal injury, homicide, etc.)

Did you reach a verdict, did the jury
hang, or was the case settled?

Were you the jury
foreperson? (Y/N)

33. Have you ever served on a grand jury?  Yes  No
If YES, did anything happen during your time as a grand juror that might affect your ability to be fair and impartial in
this case?  Yes  No
If YES, please explain: _____________________________________________________________________________
_______________________________________________________________________________________________
Were you the grand jury foreperson?  Yes  No
34. Have you read or heard anything about this lawsuit between US Airways and Sabre?  Yes  No  Unsure
Please describe what you have read or heard:
35. Putting aside this case, have you read or heard anything about any lawsuit involving US Airways, American Airlines,
or Sabre?  Yes  No  Unsure
Please describe what you have read or heard:
36. Is there anything about the nature of the arguments summarized on the first page or the parties involved that will
make it difficult for you to consider the evidence, the arguments of the attorneys, and the Court’s instructions on
the law, with an open mind?  Yes  No
If YES, please explain:
37. Do you have any difficulty speaking or reading the English language?  Yes  No  Unsure
If YES or UNSURE, please explain:
38. Do you have any difficulty with your sight or hearing that could affect your perception of the trial?
 Yes  No  Unsure
If YES or UNSURE, please explain:
39. Do you or a family member have a medical condition that may interfere with your ability to serve as a juror?
 Yes  No  Unsure
If YES or UNSURE, please explain:
40. Are you the primary caretaker for someone in need of daily care or assistance?  Yes  No
If YES, please explain:
41. Will you be paid your regular salary while serving as a juror?  Yes

7

 No

 Not applicable

Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 15 of 17
Juror ID: _______________

42. This trial is expected to last approximately four weeks beginning Friday April 22, 2022, and continuing Monday to
Thursday thereafter. Do you have a severe hardship that would prevent you from serving as a juror in this case?
 Yes  No  Unsure
If YES or UNSURE, please explain:

43. Is there any reason (e.g., religious or philosophical) you would you find it difficult to serve as fair and impartial juror
in this case?  Yes  No  Unsure
Please explain:

44. Is there anything else that you think the Court or the parties should know about you?  Yes  No  Unsure
If YES or UNSURE, please explain:

45. Have you, a family member or anyone close ever had a personal or professional connection to any of the below
companies or individuals (other than what you have already described above)? If yes, please circle the name and
explain the nature of the relationship in the lines provided below.
Companies:
US Airways
American Airlines
Sabre
Travelport
Amadeus
Orbitz

Trachtenberg Rodes & Friedberg LLP
O’Melveny & Myers LLP
Yetter Coleman, LLP

Skadden Arps, Slate, Meagher & Flom LLP
Cleary Gottlieb Steen & Hamilton LLP
Cravath, Swaine & Moore LLP

Individuals:
Al Lenza
Alex Zoghlin
Andrew Frackman
Andrew Menkes
Andrew Nocella
Andrew Winterton
Anton Melitsky
Beverly Goulet
Bill Brindle
Boris Bershteyn
Brett Berman
Bridget Blaise-Shamai
Bryce Callahan
Candi Clarke

David Gross
David Korn
David Trachtenberg
Derek Moore
Dhiren Fonseca
Dirk Guenther
Douglas Parker
Evan Chesler
Evan Kreiner
Evan Levicoff
Gavin Malloy
George Cary
Glenn Wallace
Graham Wareham

Carl Malm

Greg Webb

Jeremy Wertheimer
Joel Smith
Joelle Cuvelier
John Gustafson
John Stow
Joseph Stiglitz
Julia York
Katrina Robson
Kay Dannenmaier
Keith Wallis
Kenneth Reinker
Kevin Murphy
Kevin Orsini
Kim Jirrels
Larry WorkDembrowski
8

Madeline Gray
Madhu Pocha
Mark Burgoz
Mark Zmijewski
Matt Beatty
Matt Cummings
Matthew Beatty
Mia Gonzalez
Michael Harbin
Michael Koetting
Michael Schmeltzer
Mike Qualantone
Patrick Fitzgerald
Patrick Jones

Robert Topel
Rory Leraris
Rosa (“Romy”) Abrantes- Metz
Rose Stratford
Ryan Travers
Sam Gilliland
Scott Kirby
Sean Menke
Sergei Zaslavsky
Seth Perelman
Shelly Terry
Stephen Arena
Steve Praven
Steve Sunshine

Peter Barbur

Steven Kaiser

Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 16 of 17
Juror ID: _______________
Charles Sultan
Chris Kroeger
Chris Wilding
Dan Garton
Daniel Kasper
David Carney

Henry Thumann
Hugh Jones
Ian Simmons
James Davidson
Jason Toothman
Jay Jones

Lea Cahill
Lev Dassin
Lindsey Sieling
Lissa Bloomgren
Louis Dudney
Madeline Gray

Peter Moll
R. Paul Yetter
Raj Varadarjan
Rich Lowry
Robert Brown
Robert Jensen

Susanna Allen
Tara Reinhart
Timothy O’Neil-Dunne
Todd Richmond
Tom Klein
Tom Trenga
Tyler Young
William Hopping
Wyatt Dowling

Explain nature of relationship:

DECLARATION

I, _____________________ declare under penalty of perjury that the foregoing answers set forth
(print name)
in this Jury Questionnaire are true and correct to the best of my knowledge and belief. I have not discussed my
answers with others, or received assistance in completing the questionnaire.
Signed this ____ day of April, 2022
____________________________________
(signature)

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Case 1:18-cv-04023-LGS Document 378 Filed 05/18/22 Page 17 of 17
Juror ID: _______________

You may use this space to finish any answers which you could not fit in the spaces provided above (include Q number):

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