Course Number: 0200121213 - New Orleans Bar Association Handout...Executive Education, Chicago, IL...

Masters of the CourtroomSM

Jury Selection

Scott R. Bickford, Martzell & Bickford Harry Rosenberg, Phelps Dunbar LLP

Theresa Zagnoli (Trial Consultant), Zagnoli McEvoy Foley LLC

Course Number: 0200121213 2 Hours of CLE

December 13, 2012 9:00 – 11:10 a.m.

SCOTT BICKFORD is a civil and criminal trial lawyer who has practiced nearly 30 years. Mr.Bickford received his law degree and bachelor of arts degree from Tulane University. During hiscareer, he has had the opportunity to participate as a trial lawyer in the defense of severalprominent criminal cases including two trials involving then Louisiana Governor Edwin Edwardsas well as the successful defense of the U.S. Attorney for the Middle District of LouisianaDonald Beckner. He has also litigated several important election challenge cases includingrepresenting Senator Mary Landrieu before the United States Senate.

Important in Mr. Bickford’s practice has been his representation of Louisiana PoliticalSubdivisions, including Plaquemines Parish and several levee boards and school districts in aneffort to remediate, reclaim and restore polluted marsh lands and to lobby for laws that protectthe citizens of Louisiana from bearing the burden of the tons of waste left behind by thepetroleum industry in our state. Presently, he is representing Plaquemines Parish in their claimagainst BP as a result of the oil spill in the Gulf. Following Katrina, he was elected co-trial chairof the Murphy Oil Class Action and was lead counsel in several other oil contamination cases. He is currently involved in the litigation surrounding the ever expanding sinkhole in BayouCorne in Assumption Parish, Louisiana.

Mr. Bickford also filed the first personal injury/death action in the Deepwater Horizon litigation.

Over the past 25 years, Mr. Bickford has also represented hundreds of seamen and land basedworkers injured through their exposure to asbestos and other toxins. He was the lead counsel inthe first of the Multi-district welding cases to be tried in Cleveland Ohio and presently representswelders in manganese poisoning cases. He has been a long time board member of the LouisianaAssociation of Justice and also sits on the Board of Governors of the American Association ofJustice. He is a member of the St. Thomas More Inn of Court. He has appeared as a legalanalyst on the O’Reilly Factor and local New Orleans television stations and continues to teachand lecture lawyers and law students on trial practice and other legal issues.

HARRY ROSENBERG Partner, New Orleans Office Practice Harry Rosenberg practices in the area of commercial litigation, concentrating in the areas of business torts, trial practice, civil rights, and white collar criminal law. Mr. Rosenberg is the regional practice coordinator of the firm’s commercial litigation practice. Prior to joining Phelps Dunbar in 1974, Mr. Rosenberg served as a judicial clerk to The Honorable Jack M. Gordon, Judge, U.S. District Court, Eastern District of Louisiana. He also served as the United States Attorney for the Eastern District of Louisiana from 1990 through 1993. Mr. Rosenberg is among a select group of lawyers, recognized in the category of Litigation, listed in a nationwide client survey published in Chambers USA: America’s Leading Lawyers for Business as well as The Best Lawyers in America and Super Lawyers. Membership / Affiliations

• Louisiana State Bar Association; New Orleans Bar Association; Federal Bar Association; American Bar Association

• National Association of Criminal Defense Lawyers • Former United States Attorneys Association • Fellow, the American Counsel Association and the Louisiana Bar

Foundation • Admitted: Louisiana: U.S. Courts for the Eastern, Middle and Western

Districts of Louisiana; Northern District of Texas; U.S. Fifth Circuit Court of Appeals; U.S. Supreme Court; Louisiana State Courts.

Contact Canal Place 365 Canal Street, Suite 2000 New Orleans, LA 70130 Direct: (504) 584-9219 Fax: (504) 568-9130 [email protected] Service Areas Appellate Litigation Commercial Litigation White Collar Defense and Regulatory Investigations Education

• Tulane University Law School, J.D., 1972; Board of Editors and Editor, Tulane Law Review

• Case Western Reserve University, B.A., 1969

Admissions

• Louisiana

Theresa Zagnoli Founding Partner, CEO

(312) 494-1700 | [email protected]

Theresa Zagnoli, founding partner and CEO of Zagnoli McEvoy Foley LLC, is a leader in the field of communication consulting

and has been providing practical trial consulting and communication solutions to attorneys and business leaders for

over 27 years. Her knowledge of the American juror has made her one of the most sought-after trial consultants in the nation.

Relying on her background in communication training and knowledge gleaned from case research, Zagnoli is especially skilled at preparing expert

witnesses to testify. Her ability to understand the issues at the heart of a case and how communication during trial or deposition really works helps

her formulate better questions and offer witnesses precise guidance on how to convey what jurors, judges or arbitrators need to know to make informed

decisions. Zagnoli’s clients commend her ability to lead her design team in

concept development for trial graphics and demonstratives, helping to ensure graphics are clear, persuasive, and effective.

Recent speaking engagements include The Motley Rice Co-Counsel Seminar

“Millennium Jurors and Beyond,” University of Chicago Booth School of Business Executive Education “Visual Verbal Non-Verbal” and “Fundamentals

of Persuasive Communication,” Defense Research Institute Inc. “Best Practices for Jury Research: How to Know When You’re Getting the Most for

Your Money,” Products Liability Advisory Council (PLAC) Fall Conference “It is

Not Your Father’s Jury Anymore,” and American Inns of Court “Bridging the Generational Divide.”

Her passion for improving communication extends to all areas of her

professional and personal life. She believes that by helping clients to improve what they say and how they say it, they will become more confident, more

successful and more effective in all aspects of their lives.

ZAGNOLI MCEVOY FOLEY LLC | CHICAGO | 312.494.1700 | ZMF.COM

http://zmf.com/

Associations and Affiliations:

Past Board Member and Past Secretary Treasurer, American Society of Trial

Consultants (ASTC)

Past President, American Society Trial Consultants Foundation

Defense Research Institute (DRI)

Selected Publications:

Zagnoli, Theresa (June 2007). “What the Jury Hears in Product Liability

Litigation: The View From Both Sides and the Middle.” LJN’s Product Liability Law & Strategy.

Zagnoli, Theresa (2007). “The Changing Image of the FDA and How it

Affects the Trial.” DRI Drug & Medical Device Seminar Course Materials.

Selected Speaking Engagements:

“Visual Verbal Non-Verbal” University of Chicago Boot School of Business

Executive Education, Chicago, IL (June 2012).

“Millennium Jurors and Beyond” The Motley Rice Co-Counsel Seminar,

Kiawah Island, SC (September 2011).

“Best Practices for Jury Research: How to Know When You’re Getting the

Most for Your Money” Defense Research Institute Inc., Chicago, IL (May

2011).

“Bridging the Generational Divide” American Inns of Court, San Diego, CA

(December 2010).

“It is Not Your Father’s Jury Anymore” PLAC Fall Conference, San Diego, CA

(October 2009).

“Fundamentals of Persuasive Communication” University of Chicago GSB,

Chicago, IL (August 2009).

Education:

Drake University, Des Moines, Iowa

Graduate work in General Psychology (1986-1988)

Bradley University, Peoria, Illinois

B.A., International Studies (1979)

ZAGNOLI MCEVOY FOLEY LLC | CHICAGO | 312.494.1700 | ZMF.COM

http://zmf.com/

1

In re: Chinese-Manufactured Drywall Products Liability Litigation United States District Court for the Eastern District of Louisiana

MDL 2047

JURY QUESTIONNAIRE

To: Prospective Jurors

Ladies and Gentlemen, these are civil cases. Plaintiffs are homeowners who claim to

have suffered property damage caused by Chinese-manufactured drywall. The defendant Interior

Exterior Building Supply (INEX) was the importer and distributor of the Chinese-manufactured

drywall installed in plaintiffs’ homes. The defendant North River Insurance Company, Inc. is an

insurer of INEX.

The parties agree that the Chinese drywall installed in plaintiffs’ homes emits sulfur

gases which can cause damage to certain components in a home, such as HVAC units,

refrigerators, electrical systems, plumbing systems, and other household items. They also agree

that the Chinese drywall installed in the homes of all Plaintiffs was not fit for its ordinary or

intended purpose, and none of the Plaintiffs would have purchased the Chinese drywall had they

known about the defective nature of the Chinese drywall at the time it was purchased. Plaintiffs

claim that the defendant INEX is liable for the damages resulting from this drywall. Defendants

deny that INEX is liable.

The parties have a right to have this case tried by a qualified, fair, and impartial jury. A

qualified and impartial jury is one that is responsible and capable and that will, without fear,

favor, bias, prejudice, passion, or sympathy, hear and decide the issues to be tried objectively,

and one that will render its verdict based solely on the evidence presented at this trial and the law

applicable to the case as given to the jury by the Court.

2

It is the law that a juror’s qualifications and impartiality may not be assumed without

inquiry. This questionnaire is designed to obtain information about your qualifications to be a

juror in this case. By use of this questionnaire, the process of jury selection may be shortened.

Please respond to the following questions as completely as possible. Please remember that the

oath you took as a prospective juror requires you to give completely truthful answers to every

question.

If you are selected to serve as a juror, this questionnaire will become part of the

Court’s permanent record, but it will not be distributed to anyone except the attorneys in the

case and the judge. If you are not selected to be a juror, this questionnaire and all copies will

be destroyed.

During questioning by the judge and the attorneys, you will be given an opportunity to

explain or expand upon any answers, if necessary. If for any reason you do not want to answer

any specific questions, please write the word “PRIVATE” next to the question, and we will

take this matter up with you in private. Otherwise, please answer all questions that apply to

you. For multiple-choice questions, please put a check next to the answer or answers that most

fit your situation. Do not write on the back of any page. If you need extra room to write, use

the last page and please remember to indicate the corresponding question number.

Since the questionnaire is part of the jury selection process, the questions must be

answered by you under penalty of perjury, and you should fill out this questionnaire by yourself

without consulting any other person.

PLEASE REALIZE THERE ARE NO RIGHT OR WRONG ANSWERS.

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Questions 1. Full Name: _______________________________________________ 2. Gender (Circle one): M F 3. Date of Birth: Age: ___________ 4. Where were you born?

Country___________________________ State______________________________ Parish/County______________________ City______________________________

5. Current address where you reside: _______________________________________

City: _________________________ Zip Code: _________ 6. How long have you lived at your current address? ______________________ 7. Do you: Own your home

Rent Have other living arrangements

If you answered, “Have other living arrangements,” please explain: ______________________________________________________________________ ______________________________________________________________________

8. Have you ever lived any place other than Louisiana?

Yes No If YES, where else have you lived?__________________________________________ ______________________________________________________________________

9. Do you have any difficulty reading or understanding English?

Yes No

4

10. Do you have any physical problem that would interfere with your ability to serve on a jury?

Yes No

If YES, please explain ____________________________________________________ ______________________________________________________________________

11. Are you regularly taking any medication that could affect your ability to serve on a jury?

Yes No

If YES, please explain ____________________________________________________ ______________________________________________________________________

12. What is your employment status?

Full Time Part Time Retired Looking for Work Unemployed Homemaker Disabled Student

13. If you are currently employed:

What is the name of your employer:__________________________________________ What is your occupation (what do you do there)?________________________________ _______________________________________________________________________ _______________________________________________________________________ How long have you worked there? _______________________

14. Are you involved in the hiring and firing of other employees?

Yes

No

5

15. Are you involved in evaluating the job performance of other employees? Yes

No 16. Do you supervise other people on the job?

Yes No

If yes, how many people do you supervise?___________________________________

17. Are you now or have you been a member of a labor union?

Yes, currently Yes, but in the past No

If yes, which union are you or were you a member of?__________________________

18. If you are not presently employed or if you have held different employment during the

last ten (10) years, please provide the name of your previous employers, the years of such employment, and your job title and duties beginning with the most recent job:

Employer:______________________________________________________________

Job title/Duties:__________________________________________________________

Years(s): _______________________________________________________________

Employer:______________________________________________________________

Job title/Duties:__________________________________________________________

Years(s): _______________________________________________________________

Employer:______________________________________________________________

Job title/Duties:__________________________________________________________

Years(s): _______________________________________________________________

Employer:______________________________________________________________

6

Job title/Duties:__________________________________________________________

Years(s): _______________________________________________________________ 19. What is your highest level of education?

Did not complete high school GED High School Technical or trade school Some college Bachelor’s degree Some graduate study Master’s or Doctoral degree

20. What is your current marital status?

Never married Married Living Together Separated Divorced Widowed

21. If applicable, what is your spouse’s or significant other’s current employment status?

Not applicable Full Time Part Time Retired Looking for Work Unemployed Homemaker Disabled Student

22. If applicable, what is the name of your spouse or significant other’s employer?

_______________________________________________________________________

What is his/her occupation (what does he/she do there)? _______________________________________________________________________

How long has he/she worked there? __________________________________________

7

23. If applicable, what is your spouse or significant other’s highest level of education:

Not applicable Did not complete high school GED High School Technical or trade school Some college Bachelor’s degree Some graduate study Master’s or Doctoral degree

24. Do you have any children?

Yes

No If YES, please fill out the chart below: Age Sex Education School or Employer/Occupation _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________

25. Have you, your spouse/partner or any member of your immediate family ever served in

the military? If so, please state:

Which branch of service?_________________________________________________

What was your/their military occupational specialty?___________________________ ______________________________________________________________________ What was your/their current or most recent rank?_______________________________

Number of years of service?________________________________________________

26. Did you vote in the last presidential election?

Yes No

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27. Did you vote in the last mayoral (or parish president) election where you live?

Yes No

28. Do you own a computer, or have routine access to one?

Yes No

29. Do you, a family member, or anyone close to you have any training or experience in the

following areas?

Check next to all areas that apply and indicate “who” (the person’s relation to you) and briefly what your/their experience or work is in the space provided. For example, next to counseling you might note in the family member/someone close box “aunt - does work in group therapy”.

AREA

YOU REALTIVE/FRIEND

Construction

Architecture/Engineering

Chemistry/Geology

Real Estate

Hardware/Building Supplies

9

Legal system (e.g., lawyer, paralegal, police officer, investigator)

Finance, Economics and/or Accounting

Government Regulatory Agency (e.g., Consumer Products Safety Commission (CPSC), Department of Housing and Urban Development (HUD)

Product design or testing

Product Manufacturing

30. Do you believe you have any special knowledge that you can rely on to help you decide a

case involving construction materials?

Yes No

If yes, please explain:_____________________________________________________ ______________________________________________________________________ ______________________________________________________________________

31. Have you or a close relative ever owned or run a business?

Yes

No If YES, please describe the type of business: ___________________________________ _______________________________________________________________________

10

32. Have you or a close relative ever been involved in the sale of products?

Yes

No If YES, please describe the involvement: ____________________________________ _____________________________________________________________________

33. Have you, any member of your immediate family, or anyone you know ever had a

complaint about the quality of construction in your/their residence?

Yes No

If yes, please explain who was involved and what happened: ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

34. Did you, any family member or close acquaintance experience property damage or

personal injury as a result of Hurricane Katrina or Rita?

Yes No

If yes, explain what property or injury you/they experienced: ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

35. Were you or any family member or close acquaintance displaced from your/their

residence as a result of Hurricane Katrina or Rita?

Yes No

If yes, explain your relationship with these individuals, and indicate if they received emergency housing assistance from FEMA: ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

11

36. Have you personally been a plaintiff or a defendant in a lawsuit?

Yes No


37. Have you been a party to a class action lawsuit?

Yes No


38. Have you or a family member ever testified as a witness in any investigation or legal

proceeding?

Yes No


39. Have you previously served on a jury (check all that apply)?

Yes, as a juror in a civil case Yes, as a juror in a criminal case Yes, as a grand juror No

If YES to any, please fill out the following chart: Date State or Federal Type of Case Verdict (if any) ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________

12

40. If you served on a jury, were you ever the jury foreperson? Yes No

41. If you have had any experience as a juror, did you find it to be a positive one?

Yes No If NO, please explain what made your experience negative: ________________________________________________________________________ ________________________________________________________________________

42. Have you or a close relative ever had an experience with an allegedly defective product

in which someone was injured?

Yes No If yes, please explain: ______________________________________________________________________ ______________________________________________________________________

43. Have you or a close relative ever had an experience with an allegedly defective product

in which something was damaged?


44. Have you or a close relative ever made a claim for injuries due to an allegedly defective

product?


13

45. Have you or a close relative ever bought a home or had one built that contained any defects of which you were not aware at the time of the act of sale?


46. Do you regularly read the warning labels on products?

Yes No

47. Have you ever remodeled or renovated your home? Yes No If YES, what was the extent of the work:

48. Have you ever remodeled a room in your house without hiring outside help?

Yes No

49. Have you heard of Interior Exterior Building Supply, L.P.?

Yes No

50. Do you have an opinion about Interior Exterior Building Supply, L.P.?

Yes No

If yes, what is that opinion? ________________________________________________ _______________________________________________________________________ _______________________________________________________________________

14

51. Have you, a family member or anyone close to you had any association, personal or professional, with Interior Exterior Building Supply, L.P.?

Yes No If yes, please explain:____________________________________________________ ______________________________________________________________________ ______________________________________________________________________

52. Do you know anyone that works for or does business with Interior Exterior

Building Supply?

Yes No If yes, please tell us who you know:_________________________________________ ______________________________________________________________________ ______________________________________________________________________

53. Have you read or heard anything about Chinese drywall?

Yes No If yes, what have you read or heard? _________________________________________________________________ _________________________________________________________________ _________________________________________________________________

54. Reports about litigation involving Chinese Drywall have, from time to time, appeared in

the press. Have you seen, heard or read anything about this case or lawsuit? (This includes not only anything you may have seen or read in the media, but also anything you might have heard from relatives, friends, co-workers, or anyone else.) Yes No

If YES, briefly describe what you have heard. ______________________________________________________________________ ______________________________________________________________________

15

55. Have you heard any reports in the press or heard anything from other sources about claims against INEX in the Chinese Drywall case? Yes No

If YES, briefly describe what you have heard, and how, if at all, you believe this might affect your ability to be a fair and impartial juror in this case. ______________________________________________________________________ ______________________________________________________________________

56. Do you believe that anything you may have heard about Chinese drywall or this case will

prevent you from fairly and impartially serving as juror in this case? Yes No

Please explain: _________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

57. Do you, a family member, or anyone close to you believe you have - or they have - a

claim concerning alleged property damage and/or injury from Chinese drywall? Please check all that apply.

Yes, me Yes, family member Yes, someone close to me No Don’t know

58. Prior to today, had you ever heard of the Consumer Product Safety Commission (CPSC)?

Yes No

59. Have you heard of Knauf Plasterboard Tianjin?

Yes No

16

60. Do you have an opinion about Knauf Plasterboard Tianjin?

Yes No


61. Have you, a family member or anyone close to you had any association, personal or

professional, with Knauf Plasterboard Tianjin?


62. Have you heard of Taihe?

Yes No

63. Have you heard of Taian Taishan Plasterboard? Yes No

64. Do you have an opinion about Taihe?

Yes No


17

65. Do you have an opinion about Taian Taishan Plastboard? Yes No If yes, what is that opinion? ________________________________________________ _______________________________________________________________________ _______________________________________________________________________

66. Have you, a family member or anyone close to you had any association, personal or professional, with Taihe?



professional, with Taian Taishan Plasterboard? Yes No If yes, please explain:____________________________________________________ ______________________________________________________________________ ______________________________________________________________________

68. Have you heard of North River Insurance Company?

Yes No

If yes, please explain:____________________________________________________ ______________________________________________________________________ ______________________________________________________________________

18

69. Do you have an opinion about North River Insurance Company?

Yes No



professional, with North River Insurance Company?


71. Do you know anyone that works for or does business with North River Insurance?

Yes No If yes, please tell us who you know:_________________________________________ ______________________________________________________________________ ______________________________________________________________________

72. Have you, a family member or anyone close to you had any association, personal or professional, with Taihe or Taian Taishan Plasterboard?

Yes No If yes, please explain:____________________________________________________ ______________________________________________________________________

19

73. Have you heard of Habitat for Humanity?

Yes No If yes, what do you know about it:____________________________________________ ______________________________________________________________________

74. Have you, a family member or anyone close to you had any association, personal

or professional, with Habitat for Humanity?


75. Have you ever done volunteer work with Habitat for Humanity?

Yes No

76. Have you heard anything about Habitat for Humanity and Chinese drywall?

Yes No If yes, please explain:____________________________________________________

______________________________________________________________________ 77. Do you have an opinion about the quality in general of products made in China?

Yes No


20

78. Do you think there is a difference in the quality of certain products produced in China versus the same products produced in the United States? Yes No

79. Have you heard any reports of problems with products made in China?

Yes No

If yes, what have you heard and when did you first hear the reports? ________________ _______________________________________________________________________ _______________________________________________________________________

80. The trial of this case may take approximately two weeks. Is there any

extraordinary hardship that you would suffer by serving on this jury for the entire time? Yes No

If yes, please state the reason(s): ______________________________________________________________________ ______________________________________________________________________

21

81. Is there any reason that would not allow you to be a fair juror in this case?

Yes No Don’t know

If yes or don’t know, please explain what the reason is: ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

The answers I have given are true and correct to the best of my knowledge. JUROR SIGNATURE: ________________________________________________________ PRINT JUROR NAME:________________________________________________________ JUROR TELEPHONE NUMBER:________________________________________________ JUROR NUMBER:____________________________________________________________ NOTE: The following are additional pages attached for your convenience if needed for

your answers.

SUPPLEMENTAL JUROR QUESTIONNAIRE

1

Thank you for taking the time to fill out this questionnaire. It will save time during jury selection. Please answer truthfully, the information you provide will be confidential and only shared with the judge, the court personnel and the trial teams.

Name: Age: EDUCATION What is the highest level of education you have completed? (check one)

Less than High School High School Diploma/GED Some College/No degree Associate’s Degree Bachelor’s Degree Post-grad Degree

MARITAL STATUS Current Marital Status:

Single Married Divorced Separated Widowed

Have you ever been married? Yes No

Spouse’s (or former spouse’s) highest level of education completed (check one):

Not applicable Less than High School High School Diploma/GED Some College/No degree Associate’s Degree Bachelor’s Degree Post-grad Degree

If you have children or step-children, please indicate for each: (a) age? (b) currently living at home? (d) occupation, if any? EMPLOYMENT What is your current work status? (check all that apply):

Full-time Part-time Student Retired Unemployed Homemaker Disabled

Your current Employer: Please describe your job duties/responsibilities: ________ How many people, if any, do you supervise in your current job?

None 1-10 11-20 20 + Spouse’s (or former) current work status (check all that apply):

Not applicable Full-time Student Retired Unemployed Part-time Disabled Homemaker

Spouse’s Employer: Please describe your spouse’s job duties/responsibilities: _______ Do you know either: Name Yes No Name Yes No

Have you ever been involved in any type of legal dispute? Yes No

If yes, were you satisfied with the outcome? Yes No Not resolved yet

Have you or has anyone close to you ever been a victim of XX? Yes No Have you or has anyone close to you ever been accused of XX? Yes No How would you describe your religious background? Currently Catholic Raised Catholic, not involved now Currently Other Raised Protestant, not involved now No religion Raised with no religion, none now Have you or has anyone close to you ever been associated in any way with XX of XX? Yes, self No Yes, someone close Yes, both Have you heard of lawsuits against XX such as XX of XX alleging XX of XX? Yes No Have you ever heard of the specific case of XX v. XX of XX in which Name abused XX? Yes No Would you have any hesitation about judging XX of XX? Yes No Would you automatically find against XX of XX without hearing any evidence? Yes No Do you have any special physical needs, which would make it difficult for you to serve as a juror in this case? Yes No The answers I have given are true and correct to the best of my knowledge. Signature Date Thank you very much for your time answering these questions.


1

Thank you for taking the time to fill out this questionnaire. It will save time during jury selection.

Name: Age: EDUCATION What is the highest level of education you have completed? (check one)

Less than High School High School Diploma/GED Some College/No degree Associate’s Degree (Major: ) Bachelor’s Degree(Major: ) Post-grad Degree(Major: )

MARITAL STATUS Current Marital Status:

Single Married Divorced Separated Widowed

Have you ever been married? Yes No

Spouse’s (or former spouse’s) highest level of education completed (check one):

Not applicable Less than High School High School Diploma/GED Some College/No degree Associate’s Degree (Major: ) Bachelor’s Degree (Major: ) Post-grad Degree(Major: )

If you have children or step-children, please indicate for each: (a) age? (b) currently living at home? (d) occupation, if any? (e) occupation of child’s spouse? EMPLOYMENT What is your current work status? (check all that apply):

Full-time Part-time Student Retired Unemployed Homemaker Disabled

Your current Employer: How long have you worked there? Please describe your job duties/responsibilities: How many people, if any, do you supervise in your current job?

None 1-10 11-20 20 + Spouse’s (or former) current work status (check all that apply):

Not applicable Full-time Student Retired Unemployed Part-time Disabled Homemaker

Spouse’s current employer: How long has he/she worked there? Please describe his/her job duties/responsibilities: EXPERIENCE/TRAINING Do you, or does anyone close to you, have any experience, education or training in any of the following subjects or related subjects? (Check all that apply) Medicine (Health care) [case related] Law [case related] [case related] [case related] [case related] [case related] [case related] [case related] If you have checked any above, please describe for each: (a) who is the person (e.g., brother, friend, cousin, etc.) (b) his/her training, education or experience Have you ever been involved in any type of legal dispute? Yes No

If yes, were you satisfied with the outcome? Yes No Not resolved yet

How long ago was the dispute? Are you, or is anyone close to you, currently involved in a lawsuit? Witness Plaintiff (filed lawsuit) Defendant (was sued) No

If Yes, please explain the nature of the lawsuit and how it affects you:

Have you or anyone close to you ever had a serious dispute with an employer? Yes No

If Yes, please explain the dispute:


2

Have you ever heard of any of the following businesses or people?

[case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No

If yes, please describe what you know about each business or person.

Have you or anyone close to you ever [Case Specific]? Yes No

If yes, [Case Specific]? If yes, did you (or they) ever [Case Specific]? Yes No If yes, please explain. If no, please explain why not.

Have you or anyone close to you ever been involved in a dispute over [Case Specific]? Yes No

If yes, please explain?

Have you ever heard of [case specific]? Yes No Have you or anyone close to you ever had experience with [case specific]? Yes No

If yes, what was the experience?

[case specific] True False [case specific] True False Based on these questions, and your answers, do you have any personal, religious, moral or philosophical reasons that would make it difficult for you to serve as a juror? Yes No

If yes, please explain:

This trial is expected to last __ weeks. Do you have any specific problems at home or on the job, which might make it difficult for you to serve as a juror in this case? Yes No

If yes, please explain:

Do you have any special physical needs, which would make it difficult for you to serve as a juror in this case? Yes No If yes, please explain: After filling out this questionnaire, if you have any questions or comments you would like to share with the Judge, the attorneys, or the parties to this case, please explain below: The answers I have given are true and correct to the best of my knowledge. Signature Date Thank you very much for your time answering these questions.

T h e r e s a Z a g n o l i

UC1 6/10

Visual Verbal Non-Verbal

1

Charm Teach

Move

2

65%

Children’s Emotional

Problems

Poor Communication isResponsible f or:Poor Communication isResponsible f or:

80% of allmarital

problems

80% of allmarital

problems

90% of jobdiscontent90% of jobdiscontent

90% of jobinability/

dysfunction

90% of jobinability/

dysfunction

80%

Marital Problems

90%

Job Discontent

3

Mastering Charm

“People will forget what you say; people will even forget what you did, but people will never forget how you made them feel.”

- Joe Pine, Author

4

Mastering Charm

5

Mastering Charm I M A G E : I n a c c u r a t e F e e d b a c k

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Mastering Charm I M A G E : I n a c c u r a t e F e e d b a c k

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Mastering Charm I M A G E : Ve s t e d i n o u r o w n i m a g e

8


9


10

Mastering Charm I M A G E : U n m a n a g e d n o n - v e r b a l b e h a v i o r

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Fa

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Mastering Charm I M A G E : P e r s p e c t i v e

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Mastering Charm

Be Likeable!

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Mastering Charm

Ten Ways

to Be More

Likeable

Theory of Reciprocity

L i k a b i l i t y - 1

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Mastering Charm H u m o r - 2

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Mastering Charm A f f e c t i o n - 3

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Mastering Charm

Affection

Healthiest Women

» Affectionate

» Sympathetic

» Sensitive to needs of others

» Understanding

» Compassionate

» Eager to soothe hurt feelings

» Warm

» Tender

» Love children

» Gentle

Healthiest Men

» Those who defend own

beliefs

» Independent

» Assertive

» Forceful

» Have leadership abilities

» Dominant

» Aggressive

A f f e c t i o n - 3

» 23

Mastering Charm

If your audience doesn’t think you care about the topic or them, they will not care about the topic or you.

E m p a t h y - 4

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Mastering Charm

“The supreme accomplishment is to

blur the line between work and play.”

- Arnold Joseph Toynbee, Philosopher

L i k e w h a t y o u d o - 5

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Mastering Charm B e g e n e r o u s - 6

26

Mastering Charm S e l f d i s c l o s u r e - 7

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Mastering Charm To u c h - 8

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Mastering Charm M i r r o r i n g - 9

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Mastering Charm

“Best way to be interesting is to be interested.”

- Stephen Covey

I n t e r e s t [ i n g ] - 1 0

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Mastering Charm

Interest[ing] Needs to Cross Gender

Women

» Get information

» Connect with others

» Talk about people

» Share feelings and

details

» Build relationships

Men

» Give information

» Set goals

» Talk about things

» Share facts, not details

» Solve problems

I n t e r e s t [ i n g ] - 1 0

» 31

Success is Attributable To:

93%

7% - Information, Intelligence, or Skill

Attitude

Source: Harvard Business School Study

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Follow Me @tzagnoli

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www.theresazagnoli.blogspot.com

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