HomeMy WebLinkAbout2021-cv-2063-CNS-MEH - City Of Fort Collins V. Open International, Et Al. - 246 - City's Proposed Voir Dire Questions
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No.: 21-cv-02063-CNS-SBP
CITY OF FORT COLLINS,
Plaintiff/Counterclaim Defendant,
v.
OPEN INTERNATIONAL, LLC
Defendant/Counterclaim Plaintiff,
and
OPEN INVESTMENTS, LLC,
Defendant.
PLAINTIFF CITY OF FORT COLLINS’ PROPOSED VOIR DIRE QUESTIONS
Plaintiff, the City of Fort Collins (the “City”), by and through its undersigned counsel,
hereby respectfully submits the following proposed voir dire questions:1
1. Do you or does anyone close to you have any training, work experience or background in
the field of:
a) Law, the justice system, or the courts
b) Contracts
c) Computers
d) Software installation/programing
1 The parties have agreed to confer and discuss the use of a questionnaire with the Court during the upcoming
September 29, 2023 Trial Conference and therefore, the City reserves the right to modify/supplement these questions
pending those discussions.
Case No. 1:21-cv-02063-CNS-SBP Document 246 filed 09/22/23 USDC Colorado pg 1 of 4
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e) Project Management
f) Municipal (City) Governance
g) The internet or providing internet service.
2. Have you (or anyone close to you) ever been in a lawsuit (other than a divorce)?
a) What kind of case?
b) What was your role (did you sue someone, or were you sued)?
c) Did the case go to the jury? Was there a verdict for the plaintiff or for the defendant?
d) If your case went to the jury, what are your general impressions of your jury
experience?
3. Have you had previous jury experience?
a) If yes, when? What court?
b) Were you the foreperson or Presiding Juror?
c) Do you understand that you are to decide the facts in this case based upon the
evidence in it, not upon anything you heard or learned in any other case in which
you were a juror?
4. Do you have any concerns whether you will be able to remain an attentive, impartial juror,
over the full length of this trial? If so, what are your concerns?
5. Has anyone here heard about this case in the media?
a) Have you formed an opinion?
6. Do you know any of the other jurors in the courtroom today?
7. Do you know any of the attorneys?
8. Has anyone here been accused of fraud or fraudulent inducement before?
Case No. 1:21-cv-02063-CNS-SBP Document 246 filed 09/22/23 USDC Colorado pg 2 of 4
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9. Has anyone here been involved in a contract dispute of any significance?
a) Looking back, do you place the blame on the other party?
10. Does anyone here know who Open International is?
a) Do you have a favorable impression of them?
11. Does anyone here know who Open Investments is?
a) Do you have a favorable impression of them?
12. Does anyone here have any significant negative experiences with the City of Fort Collins?
13. Does anyone here have any particularly strong anti-government opinions?
Respectfully submitted this 22nd day of September, 2023.
DORSEY & WHITNEY LLP
s/ Case Collard
Case Collard
Andrea Ahn Wechter
Maral J. Shoaei
1400 Wewatta Street, Suite 400
Denver, Colorado 80202-5549
Telephone: (303) 629-3400
Fax: (303) 629-3450
E-mail: collard.case@dorsey.com
E-mail: wechter.andrea@dorsey.com
E-mail: shoaei.maral@dorsey.com
Attorneys for Plaintiff City of Fort Collins
Case No. 1:21-cv-02063-CNS-SBP Document 246 filed 09/22/23 USDC Colorado pg 3 of 4
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CERTIFICATE OF SERVICE
I hereby certify that on September 22, 2023 I caused the foregoing document to be
electronically filed via CM/ECF system which will send notification of such filing to all counsel
of record.
s/ Stacy Starr
DORSEY & WHITNEY LLP
Case No. 1:21-cv-02063-CNS-SBP Document 246 filed 09/22/23 USDC Colorado pg 4 of 4