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HomeMy WebLinkAbout2021-cv-2063-CNS-MEH - City Of Fort Collins V. Open International, Et Al. - 244 - Open's Proposed Voir Dire Questions IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 2021-cv-02063-CNS-SBP CITY OF FORT COLLINS, Plaintiff and Counter-Defendant, vs. OPEN INTERNATIONAL, LLC, Defendant and Counterclaimant, and OPEN INVESTMENTS, LLC, Defendant. OPEN INTERNATIONAL’S PROPOSED QUESTIONS FOR THE COURT’S INITIAL VOIR DIRE Pursuant to CNS Civ. Standing Order III.E, Defendants and Counterclaimant Open International, LLC and Open Investments, LLC (together, “Open”) respectfully submit the following proposed voir dire questions: 1. Please describe your current or most recent job, including your employer, title, and primary responsibilities. 2. If you live with a spouse or a partner, please describe your spouse or partner’s current or most recent job, including their employer, title, and primary responsibilities. 3. Do you or any of your family members or close friends have any specialized training, education, or experience in: a. Law or the legal system Case No. 1:21-cv-02063-CNS-SBP Document 244 filed 09/22/23 USDC Colorado pg 1 of 4 2 b. Municipal utilities c. Broadband Internet systems 4. Please let me know where you live (generally) and how long you have lived in Colorado. 5. Have you ever worked for a government entity, like a city, town, county, state or associated agency? If so, please describe your role and whether you have had favorable or unfavorable experiences in that role. 6. Have you ever worked in management or leadership of any of the businesses or organizations you have worked with? If so, please describe your role and whether you have had favorable or unfavorable experiences in that role. 7. Have you ever been involved in negotiating or interpreting contracts or other business agreements? If so, please describe that experience. 8. Have you ever had a significantly negative experience in feeling like you have been taken advantage of by a contractor, or someone you contracted to do work for you? Can you tell me about that experience? 9. Have you served on a jury in the past? If so, please describe where and when, as well as the nature of the case. 10. Have you ever been involved in a lawsuit, other than a divorce? If so, please generally describe the circumstances of the lawsuit and your role in it. 11. Do you have any opinions of lawsuits, the law, or the legal system that might affect your ability to be fair and impartial? Is so, please tell me about those opinions. 12. Please summarize any organizations you belong to, or regularly support, including volunteer work. 13. What local or national newspapers, magazines, and/or websites do you typically use to get information on news and current events? Dated: September 22, 2023. Case No. 1:21-cv-02063-CNS-SBP Document 244 filed 09/22/23 USDC Colorado pg 2 of 4 3 Respectfully submitted, s/ Kevin C. McAdam Paul D. Swanson Kevin C. McAdam Alexander D. White Alexandria E. Pierce Holland & Hart LLP 555 17th Street, Suite 3200 Denver, Colorado 80202 Telephone: 303-295-8000 pdswanson@hollandhart.com kcmcadam@hollandhart.com adwhite@hollandhart.com aepierce@hollandhart.com Attorneys for Defendants Open International, LLC and Open Investments, LLC Case No. 1:21-cv-02063-CNS-SBP Document 244 filed 09/22/23 USDC Colorado pg 3 of 4 4 CERTIFICATE OF SERVICE I hereby certify that on the 22nd day of September, 2023, the foregoing was electronically filed with the Clerk of Court using the Court’s electronic filing system and that a copy of the foregoing was sent to all counsel of record via same in compliance with the Federal Rules of Civil Procedure and the Local Rules of this Court. s/ Kevin C. McAdam 30566464 Case No. 1:21-cv-02063-CNS-SBP Document 244 filed 09/22/23 USDC Colorado pg 4 of 4