343 D Prop Joint Juror Questionnaire

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Mark A. Wasser CA SB #060160 LAW OFFICES OF MARK A. WASSER 400 Capitol Mall, Suite 2640 Sacramento, California 95814 Phone: (916) 444-6400 Fax: (916) 444-6405 E-mail: [email protected]

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Attorney for Defendant County of Kern

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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. Plaintiff,

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Case No.: 1:07-cv-00026-0WW-DLB

DEFENDANT'S PROPOSED JOINT JUROR QUESTIONNAIRE

vs.

COUNTY OF KERN, et aI., Defendants.

Date: May 12,2009 Time: 9:00 a.m. Place: U.S. District Court, Courtroom 3 2500 Tulare Street, Fresno, CA Date Action Filed: January 6, 2007

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DEFENDANT'S PROPOSED JOINT JUROR QUESTIONNAIRE

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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 issues 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 intended to invade your privacy or make you uncomfortable.

PLEASE PRINT YOUR ANSWERS. IF THERE IS NOT ENOUGH ROOM FOR YOUR ANSWER, PLEASE ATTACHA BLANK PIECE OF PAPER. WRITE THE QUESTION NUMBER NEXT TO YOUR ANSWER.

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I Full Name:

Male Gender: Female Ae:e: In which county do you currently live (do not give your address): 2. With regard to your home: Calaveras Fresno _Inyo Kern _Kings - Own - House Apartment Madera Mariposa Merced Stanislaus Tulare Rent 4. Is English your first language? Yes Date and Place of Birth: No IF NO, what is? Your current or most receut occupation: 6. Your current marital status: Divorced for _yrs _Never married, living alone _Separated for _ yrs _Engaged yrs yrs Married or partnered Widowed for Your present employment status (check all that apply): _ Employed full time _ Employed part-time _ Unemployed, looking for work Retired Homemaker Unemployed, not looking for work Student What are your specific duties and responsibilities at work?

Juror #

9. a. Do yon supervise others? _

Yes If yes, how many? No b. Do vou have authority to discipline, hire or fire otbers? 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): II. All other employment you have had (and for how long):

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

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

14. Are you or is anyone close to you a member of a labor union? - Yes No If yes, explain: 16. Have you or has anyone close to you ever sned or been sued in any type oflawsuit. - - Sued -- Been Sued Explain:

15. Have you ever been on a jury before? Yes - No Criminal? Was it: Civil? Yes No If ves, did von reach a verdict? 17. Do you feel that money damages in lawsuits are (check one): _ Often too large - - Often too low _ Other (specifY): _ About right

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

19. Have you ever been involved in disciplining or terminating someone or implementing a layoff? - Yes - - No Tfyes, explain:

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

21. Generally, how fair do you think employers are to their employees? _Very - Somewhat fair _Not very - Not at all

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

23. Have you or anyone close to you ever received treatment from a psychiatrist or psychologist? Yes No - If yes, explain:

24. Do you agree or disagree with awarding someone money damages for: __ Disagree Past future wage loss: _ Agree __ Disagree _Agree Future wage loss: Pin, suffering and emotional distress? Agree Disagree 26. Some people think we as a society have gone overboard trying to accommodate workers with disabilities and/or medical condition. Do you _Agree or _Disagree Explain:

25. Have yon ever felt as though your workload or position was affected by a co-worker being on medical or disability leave or restrictions? _ Yes No

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

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28. Do you have auy particularly positive or negative impression of Kern Medical Center? Yes - No If yes, describe:

30. Do you believe there should be limits ou the 29. Have you or anyone close to you ever worked ability to sue government agencies? _ Yes - No for the Couuty of Kern or auy other governmeut agency? Yes No 31. This case involves a dispute between an employer and an employee who claims a disability. Is there any No reason why you might not be an appropriate juror in a case with that issue? _ Yes 32. Describe any problems (vision, hearing, dental or other medical problems) that might affect your jury Service. 33. Do you have any ethical, religious, political or IF YES TO 30 and/or 31, please explaiu: other beliefs that might prevent you from serving as a juror? Yes No 34. Is there anything not covered by this questionnaire that might affect your ability to be a fair and impartial juror? Yes No 35. The attorneys may need to ask you follow-up questions. Are there any questions you would prefer to discuss in private? Yes No 36. How would you describe your political orientation? Very liberal Very conservative I 2 3 4 6 5 7 37. How much coufidence do you have in major companies in our country? None at all Very much I 3 2 4 5 6 7 38. How much confidence do you have in our financial institutions? I 3 Very much None at all 2 4 6 5 7 39. Please give an opinion about how much money our system is spending on welfare: I Far too little 2 3 4 6 Far too much 5 7 40. In spite of what people say, conditions for the average person are getting worse, not better.

Strongly Disagree 7 I 2 3 5 Strongly Agree 4 6 41. It is hardly fair to bring a child into the world with the way things look for the future: Strongly Agree Strongly Disagree I 2 3 4 5 6 7 42. Most public officials are not really interested in the problems of the average person: Strongly Disagree 7 I 2 3 Strongly Agree 4 5 6 43. How often do you feel that people are too quick to sue rather than settling disputes? Never

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44. To what extent do you believe that people should accept the cards they are dealt iu life? None at all

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Very much

45. To what extent do you believe that people generally "bring on" what happens to them? Very much None at all I 2 3 4 5 6 7 46. To what extent do you believe that it is worth the effort for people to try to change their lot in life? 4 Very much None at all I 2 3 5 6 7 47. To what extent do you believe that peoples' futures are determined mostly by fate? 4 None at all I 2 3 5 6 Vervmuch 7 48. To what extent do you believe that people usually get what they deserve in life? None at all I 3 4 Vervmuch 2 5 6 7 49. To what extent do you believe that wheu people meet with misfortune, it is usually through uo fault of their own? None at all I 2 3 4 Vervmuch 5 6 7 50. To what extent do you believe that good deeds in life usually go unnoticed and unrewarded? None at all I 2 3 4 Very much 5 6 7 51. To what extent do you believe that whether or not people like you usually depends on how you act? Not at all I 2 3 4 Very much 5 6 7 52. To what extent do you believe you can often influence what happens in the future by things you do today? Not at all I 3 4 2 5 6 Vervmuch 7 53. To what extent do you believe that, when bad things are going to happen, they are usually going to happen, no matter what you do? Not at all I 2 3 4 5 6 7 54. Which would you rather have on your side - brains or luck?

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] Luck 2 3 4 5 Brains 6 7 55. How much of your working life has involved supervising other employees?

] None of it 2 3 4 5 All of it 6 7 56. How much do you tend to participate when you are in a discussion group?

Not at all I 2 3 4 5 6 Vervmuch 7 57. How often do you find yourselffunctioning as one of the leaders in group situations? Never I 3 4 Very frequent]v 2 5 6 7 58. How often have you been selected to head or preside over a group? Never

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59. Have you ever seen auy movies or TV shows that depict someone with depressiou? Yes No 60. Have you ever read books or magaziue articles about depression? Yes No 61. Have you ever provided care for someone who was diagnosed with depression? Yes No 62. What is your general understanding of depressiou?

Signature:

_

Thank you. Please return this completed Questionnaire to the Clerk.

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