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
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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.
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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
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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
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