IN THE CIRCUIT COURT FOR PRINCE GEORGE’S COUNTY, MARYLAND

STEVEN SPAID - Plaintiff

v

SANDRA STEVENS- Defendant

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CASE NO.: 03-C-04-099273 MT
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PLAINTIFF’S VOIR DIRE

      Plaintiff, Steven Spaid by and through his attorneys, Ronald V. Miller, Jr., Laura G. Zois, and Miller & Zois, LLC, and requests that this Court propound the following questions to the prospective jurors in the above-captioned matter:

     1. This is a personal injury case involves a car accident which took place on February 10, 2013, in Prince George’s County, Maryland, on southbound Point Pleasant Road near its intersection with Smith Avenue. The Plaintiff was lawfully operating his motor vehicle when he was struck head-on by the Defendant, who was traveling northbound on Point Pleasant Road, causing the Plaintiff severe injuries and property damage. Does any member of the jury panel have any personal knowledge of this incident?

     2. The parties of the case are as follows:
          A. Steven Spaid, the Plaintiff
          B. Sandra Stevens, Defendant
          Is any member of the jury familiar with any of the parties in this case or employed by any of the parties in this case?

      3. The attorneys in the case are as follows:
          A. Laura G. Zois, for the Plaintiff with Miller & Zois
          B. Ronald V. Miller, Jr. for the Plaintiff with Miller & Zois
          C. Michael Kodek, Esquire, for the Defendant
          Is any member of the jury panel familiar with the attorneys in this case or their law firms?

      4. The following fact witness may testify in this case:
          A. Karol Sopel
          B. Officer Brian Kase
          C. Laura Kahl
          D. Mary Ann Dutton
          Is any member of the jury panel familiar with any of these witnesses?

      5. This case involves medical treatment from the following healthcare providers and medical expert witnesses.
          A. University of Maryland Shock Trauma Center
          B. Miles L. Gerber, M.D.
          C. Jeff P. O’Hearn, M.D.
          D. Larry St. Laurent, Ph.D.
          E. Doug Strauss, Ph.D.
          F. Michael McGinnis, vocational rehabilitation expert
          G. Larry Sanders, vocational rehabilitation expert
          Is any member of the jury panel familiar with any of the following doctors or treatment facilities? Has any member of the Jury panel been a patient or employee of any of these doctors of healthcare facilities?

      6. Have you, any member of your immediate family or close personal friend been involved in a lawsuit or claim against another person, as either the party bringing the claim or defending the claim? The claims would include any injury or damage, including a car accident, worker’s compensation claim, assault and battery, or a slip and fall? If so would that experience affect you ability to be fair and impartial in this case?

      7. Have you, any member of your immediate family or close personal friend been injured in an accident that was caused by another person’s negligence? Or, have you been involved in a accident that was your responsibility that resulted in another persons injuries? If so, would that experience affect your ability to be fair and impartial in this case?

      8. Have you, any member of your immediate family or close personal friend ever been diagnosed with a knee injury ? If so would that experience affect your ability to be fair and impartial in this case?

      9. Have you, any member of your immediate family or close personal friend ever had a knee surgery? If so, would that experience affect your ability to be fair and impartial in this case?

      10. Have you, any member of your immediate family or close personal friend ever worked in the medical field? If so, would that experience affect your ability to be fair and impartial in this case?

      11. Have you, any member of your immediate family or close personal friend ever worked in the legal profession? If so, would that experience affect your ability to be fair and impartial in this case?

      12. Have you ever served on a jury before. If so, would that experience affect your ability to be fair and impartial in this case?

      13. Do you have any preconceived notions, prejudices or feelings about people who bring lawsuits or make claims for injuries they have sustained arising out of someone else’s negligence?

      14. Have you ever received any information from any source about “Tort Reform” legislation, a supporter of Tort Reform or a member of any Tort Reform organization or group? [Note: it is tough to get a judge to ask this question. Still, many do because they want to get to the bottom of who has preconceived opinion that show a strong bias against one party. Oh, who am I kidding? Okay, a strong bias against plaintiffs.]

      15. Do you feel that you would have any difficulty in following the Court’s instructions on the law?

      16. Have you had any personal experiences that you believe would prevent you from rendering a fair and impartial verdict in this personal injury case?

      17. Do you have any physical problems or personal commitment problems that would prevent you from sitting on this jury for two days?

      18. Do you believe that you would have any problem for any reason rendering a fair and impartial verdict for any reason?

      19. Do you have any bias at all towards the plaintiff for brining the lawsuit against the Defendant or any bias towards the Defendant for defending the claim?

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