UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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KAREEM SHAMEL PERRY, |
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Plaintiff, |
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v. |
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99-CV-4934 (LAP) |
CHARLES GREINER; Q. MAGWOOD; |
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R. HUMLOCK; M. HUGHES; D. BENNETT; |
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AND M. BARNES, |
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Defendants. |
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PLAINTIFFS PROPOSED VOIR DIRE QUESTIONS
- was the perpetrator punished?
- were you satisfied with the result?
- what rank did you hold?
- what duties did you have?
- were you ever in the military police?
- What is your relationship with that person?
- What was the person imprisoned for?
- How long was the sentence?
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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KAREEM SHAMEL PERRY, |
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Plaintiff, |
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v. |
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99-CV-4934 (LAP) | ||
CHARLES GREINER; Q. MAGWOOD; |
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R. HUMLOCK; M. HUGHES; D. BENNETT; |
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AND M. BARNES, |
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Defendants. |
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STATE OF NEW YORK |
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COUNTY OF NEW YORK |
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DALE R. COLLINGWOOD, being duly sworn, deposes and says:
Lee Adlerstein
Office of the Attorney General
Of the State of New York
120 Broadway
24th Floor
New York, NY 10271
212-416-6009
DALE R. COLLINGWOOD
Sworn to before me this
18th day of April, 2001
Notary Public
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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KAREEM SHAMEL PERRY, |
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Plaintiff, |
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v. |
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99-CV-4934 (LAP) (THK) |
CHARLES GREINER; Q. MAGWOOD; |
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QUESTIONS TO VOIR DIRE |
R. HUMLOCK; M. HUGHES; D. BENNETT; |
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AND M. BARNES, |
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Defendants. |
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Introduction
In this action, plaintiff Kareem Shamel Perry complains that, while located at the Sing Sing Correctional Facility, the defendant correctional officers Magwood, Hunlock, Bennett and Barnes used or caused the use of excessive force against him. Plaintiff claims that correctional officer Hughes caused another inmate to attack and injure plaintiff. The correctional officers deny that they used excessive force or caused a physical attack against plaintiff.
Personal contact with law enforcement
- In what capacity?
- Does the person you know in law enforcement speak to you about their work?
- Is there anything about the connection you or the person you know has to law enforcement which might make it difficult for you to be fair and impartial in this case?
- Do you think that your connection with law enforcement would make you tend to favor or disfavor the testimony of the corrections officers in this case?
General interaction with law enforcement
- Have you ever asked a police officer for directions?
- Have you ever been pulled over for a traffic violation?
- Have you ever been the victim of a crime and interacted with police who handled the case?
In each case, was your impression of the law, enforcement person you interacted with negative or positive? (May go into facts depending on reaction).
Do you think that your impression of that law enforcement person would have an influence on how you might view the corrections officers in this case? Or could you separate your feelings about your prior contact with law enforcement and not hold it against these corrections officers?
Interaction with Corrections Officers
How do you think that you or that person was treated at the time?
- If so, what has been your impression of the corrections or parole officer(s) that you or your family member interacted with?
- Do you feel that the officer(s) treated you or the person you know fairly?
- Do you feel that your impression of such officers(s) would affect how you might view the officers who will be testifying in this case?
- Or could you separate your impressions of that officer whom you or the person you know interacted with and not carry it over to this case?
Use of Force
- Do you think that those accounts are so disturbing to you that you would have a difficult time being a fair and impartial juror in this case?
- Do you think that these accounts would make it difficult for you to listen impartially to the testimony of the corrections and other state officers in this case? Would you hold those images against these particular officers?
- Do any of you think that there is ever a time when a law enforcement officer is justified in using some force?
- Based upon incidents in the news regarding the use of excessive force, and as you sit here now before hearing any testimony in the case, would it be difficult for you to believe that the corrections officers acted reasonably in the present case?
Or could you keep an open mind and hear all the testimony of the witnesses before and consider all the circumstances in deciding whether the corrections officers acted properly.
Dated: New York, New York
April 17, 2001
Respectfully submitted,
ELIOT SPITZER Attorney General of the
State of New York
Attorney for State Defendants
By:
LEE ALAN ALDERSTEIN (LA-7897)
Assistant Attorney General
12 0 Broadway
New York, New York 10271
(212) 416-8576
SAMPLE VOIR DIRE QUESTIONS
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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[PLAINTIFF], |
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Plaintiff, |
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-- against -- |
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____ Civ. ____ ( ) |
[DEFENDANT], |
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PLAINTIFFS or DEFENDANTS |
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PROPOSED |
Defendants. |
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VOIR DIRE QUESTIONS |
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These general questions are usually asked of all jurors regardless of the type of case:
Background Questions:
Prior Court Experience:
The following are examples of questions designed to elicit information from jurors which may call into question their ability to be fair and impartial to either side.
Prisoners Civil Rights:
Employment Discrimination: