341 P Prop Joint Juror Questionnaire

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LAW OFFICE OF EUGENE LEE Eugene D. Lee (SB#: 236812) 555 West Fifth Street, Suite 3100 Los Angeles, CA 90013 Phone: (213) 992-3299 Fax: (213) 596-0487 email: [email protected] Joan Herrington, SB# 178988 BAY AREA EMPLOYMENT LAW OFFICE 5032 Woodminster Lane Oakland, CA 94602-2614 Telephone: (510) 530-4078 Facsimile: (510) 530-4725 Email: [email protected] Of Counsel to LAW OFFICE OF EUGENE LEE Attorneys for Plaintiff DAVID F. JADWIN, D.O.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DAVID F. JADWIN, D.O.,

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Plaintiff,

Civil Action No. 1:07-cv-00026 OWW DLB PLAINTIFF’S PROPOSED JOINT JUROR QUESTIONNAIRE

v. COUNTY OF KERN,

Complaint Filed: January 6, 2007 Trial Date: May 14, 2009

Defendant.

19 20 Pursuant to the Court’s Pre-Trial Order, Plaintiff respectfully submits this Plaintiff’s Proposed 21 Joint Juror Questionnaire attached hereto as Exhibit 1, and incorporated by reference herein. 22 23 Dated: May 10, 2009. 24

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/s/ Eugene D. Lee SB# 236812 LAW OFFICE OF EUGENE LEE 555 West Fifth Street, Suite 3100 Los Angeles, California 90013 Telephone: (213) 992-3299 Facsimile: (213) 569-0487 Email: [email protected]

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Attorney for Plaintiff DAVID F. JADWIN, D.O.

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JUROR QUESTIONNAIRE United States District Court, Fresno Division Judge Oliver W. Wanger INSTRUCTIONS: Thank you for coming to court as a potential juror. The judge and the people involved in this case need to know some things about you to select jurors who can be fair to both sides. As a juror, you must return a verdict based on the law and on the facts proved in court, not on emotion or on other views or facts not supported by the evidence. The judge will give you instructions on the law and on how you should go about deciding the case. You must listen to and follow the judge’s instructions. Of course, everyone has attitudes and opinions which come from their life experiences that they bring into the courtroom. Sometimes these experiences can make it difficult to look at a certain issue in an unbiased and unemotional way. The questions on this form are designed to address that concern to ensure that you can be a fair and impartial juror for this case. They are not asked to invade your privacy or make you uncomfortable. If there is any reason why you might not be able to give both sides a fair trial in this case, you have a duty to say so. PLEASE PRINT YOUR ANSWERS. IF THERE IS NOT ENOUGH SPACE, PLEASE ATTACH A BLANK PIECE OF PAPER. WRITE THE QUESTION NUMBER NEXT TO YOUR ANSWER. Juror #

Full Name:

Gender: Age:

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In which county do you currently live (do not give your address): Calaveras Fresno Inyo Kern Kings Madera Mariposa Merced Stanislaus Tulare

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Date and Place of Birth:

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Your current or most recent occupation:

Your current marital status: Never married, living alone Engaged Married or partnered, yrs

7.

Your present employment status (check all that apply): Employed part-time Retired Homemaker Student

8.

What are your specific duties and responsibilities on the job?

9. a. Do you supervise others? Yes No If yes, how many? b. Do you have authority to discipline, hire or fire others?

Male

2. With regard to your home: Own House Rent Apartment

4. Is English your first language? IF NO, what is? 6.

Female

Yes

No

Divorced for Separated for Widowed for

years years years

Employed full time Unemployed, looking for work Unemployed, not looking for work

Yes

No

10. Your highest level of education completed: Grade school or less Technical or vocational school (major): High school graduate College graduate (major): Some college or AA degree Post graduate study (major): Other (please explain):

11.

All other employment you have had (and for how long):

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12. All full-time employment of your spouse or any person with whom you have a significant personal relationship (and for how long):

13. Have you or has anyone close to you had training or work experience in any of the following? Medical services Mental health services Insurance claims Human resources Workplace discrimination Law If you have checked any of the above, please explain:

Describe any offices held:

15. Are you or is anyone close to you a member of a labor union? Yes No If yes, explain:

16. Have you ever been on a jury before? Yes No Civil? Criminal? Was it: If yes, did you reach a verdict? Yes No

17. How satisfied would you say that you are with your current financial situation? Very More or Less Not very satisfied

18. Have you or has anyone close to you ever sued or been sued in any type of lawsuit, explain: Sued Been Sued Explain:

19. Do you feel that money damages in lawsuits are (check one): Often too large Often too low About right Other (specify):

20. Do you agree or disagree with awarding someone money damages for: (do you have a problem with ) Past wage loss: Agree Disagree Agree Disagree Future wage loss: Pain, suffering and emotional distress? Agree Disagree

21. Have you, or has anyone close to you, ever been accused of or been a victim of discrimination in a job situation? (experience questions) Yes, I have Yes, someone close has No If yes, explain:

22. Have you or someone close to you ever been accused of or been a victim of inappropriate or unfair Yes No treatment in a job situation? (experience questions) If yes, explain:

23. How much of a problem is discrimination in the workplace? (attitude questions) Large problem Somewhat of a problem Not a problem

24. Have you, or has anyone close to you, ever been demoted, terminated, or laid off from a job? Yes, demoted Yes, terminated Yes, laid-off No If yes, explain:

25. Have you ever been involved in disciplining or terminating someone or implementing a lay off? Yes No If yes, explain:

26. Have you or anyone close to you ever missed a significant amount of time from work for health Yes No reasons (excluding pregnancy)? If yes, explain:

27. Have you ever felt as though your workload or position was affected by a co-worker being on medical or Yes disability leave or restrictions? No(experience questions) If yes, explain:

14. What social, civic, professional, trade, or other organizations are you affiliated with?

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28. Generally, how fair do you think employers are to their employees? Very Somewhat fair Not very Not at all

29. Do you believe that most employees today don’t take enough responsibility for their own actions? (attitude) Yes No If yes, explain:

30. Do you believe that many people use claims of discrimination or harassment as an excuse for their own shortcomings or poor work performance? Yes No (attitude) If yes, explain:

31. Do you believe there are too many governmental restrictions on what employers can and cannot do regarding their employees? Yes No (attitude) If yes, explain:

32. Some people think that we as a society have gone overboard trying to accommodate workers with disabilities and/or medical conditions. Do you: Agree or Disagree? (fundamental attitude questions) Explain:

33. Have you or a family member been diagnosed with anxiety or depressive disorder? Yes No If yes, explain:

34. Have you or anyone close to you ever received treatment from a psychiatrist or psychologist for a major mental illness? Yes No If yes, explain:

35. Have you or anyone close to you ever worked at, been a patient at, or had any other contact with Kern Medical Yes No Center (KMC)? If yes, explain:

36. Do you have any particularly positive or negative impressions of Kern Medical Center (KMC)? Yes No If yes, describe:

37. Have you or anyone close to you ever worked for the County of Kern, or any other public or governmental agency? Yes No

38. Have you or anyone close to you ever worked for the County of Kern or any other government agency?

39. This case involves a dispute between an employer and an employee with a disability. Is there any reason why you might not be an appropriate juror in a case with Yes No these issues?

Yes

No

40. Describe any problems (vision, hearing, dental or other medical problems) that might affect your jury service.

41. Do you have any ethical, religious, political or other beliefs that might prevent you from serving as a juror? Yes No

IF YES TO 41 and/or 42, please explain:

42. Is there anything not covered by this questionnaire that might affect your ability to be a fair and impartial juror? Yes No 43. The attorneys may need to ask you follow up questions. Are there any questions you would prefer to discuss in private? Yes No

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44. How much confidence do you have in major companies and financial institutions in our country? None at all

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Very much

45. In spite of what people say, conditions for the average person are getting worse, not better. Strongly Disagree

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Strongly Agree

46. Most public officials are not really interested in the problems of the average person: Strongly Disagree

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Strongly Agree

47. How often do yon feel that people are too quick to sue rather than settling dispntes? Never

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Very frequently

48. To what extent do you believe that when people meet with misfortune, it is usually because of their own fault? None at all

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Very much

49. How much of your working life has involved supervising other employees? None of it

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All of it

50. How often do you find yourself functioning as one of the leaders in group situations? Never

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Very frequently

51. Have you ever seen any movies or TV shows that depict someone with depression? Yes _______________

No _______________

52. Have you ever read books or magazine articles about depression? Yes _______________

No _______________

53. Have you ever provided care for someone who was diagnosed with depression? Yes _______________

No _______________

54. What is your general understanding of depression?

55. Have you, or anyone in yonr family, ever been misdiagnosed by a doctor? Yes _______________ No _______________ 56. Have you, or anyone in your family, ever had a severe reaction to a medicine prescribed by a doctor? Yes _______________

No _______________

57. Has a doctor ever saved your life or the life of anyone in your family? Yes _______________

No _______________

Thank you. Please return this completed Questionnaire to the Clerk. USDC, ED Case No. 1:07-cv-00026 OWW DLB JUROR QUESTIONNAIRE

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