Standard Voir Dire Jury Questionnaire

         Good day, I am Judge Theodore Campagnolo of the Coconino County Superior Court.
 
         You have been randomly selected as a potential juror in the case of:
 
           HARMINDER SAMRA VS HOLBROOK MOTEL INVESTORS, LLC., HOLBROOK MOTE PARTNERS, LLC, HOLBROOK MOTEL INVESTMENTS, INC, UMRIK SINGH, SATINDER GILL, JOGA S. MANN, GURJIT S. SEHKON, AND SHASHIKANT PATER
 
           Jury duty is one of the most important civic duties citizens of this country are called upon to perform.  I know that you will not take this duty lightly.
 
           I know that jury service is an inconvenience to you to one extent or another.  And I know how important it is to our community that persons such as yourselves are willing to serve on juries to decide cases such as this one.
 
             It is necessary to ask you some questions to find out if you have any knowledge about this case or about any of the persons who might be involved in it; to find out if you have any preconceived opinions about the case which you might find difficult to lay aside; and to find out if you have any personal or family experiences that might cause you to identify yourself with either of the parties.  These questions are not designed to pry unnecessarily into your personal lives or affairs.  We ask them only to assure we select a fair and impartial jury.
 
Please do not withhold any information in order to be seated on the jury.  Do not be concerned with whether your answers are “right” or “wrong”; this is not a test.  Just be honest and candid in your answers, and do not be concerned with what
you feel the lawyers, or I might want to hear from you.
 
            THESE NEXT QUESTIONS ASK FOR PERSONAL INFORMATION.  PLEASE UNDERSTAND ONLY THE ATTORNEYS AND THE JUDGE WILL HAVE ACCESS TO THIS INFORMATION.  PLEASE DO NOT WITHHOLD YOUR ANSWER.  AT THE END OF JURY SELECTION, THESE QUESTIONNAIRES WILL BE DESTROYED.
 
            WHEN YOU APPEAR IN COURT, YOU WILL BE REQUIRED TO SWEAR OR AFFIRM THAT YOU HAVE TRUTHFULLY ANSWERED ALL QUESTIONS CONTAINED IN THIS QUESTIONNAIRE.
 

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* 1. Contact Information

There are certain minimum qualifications that you must meet to be a potential juror in this case.

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* 2. Are you age 18 or older?   

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* 3. Are you a citizen of the United States?

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* 4. Have you ever been convicted for a felony?

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* 5. If yes, have you had your rights restored?

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* 6. Are you mentally incompetent or under a guardianship?

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* 7. Do you live in Coconino County?

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* 8. Do you have difficulty reading or understanding the English language?

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* 9. Do you need any assistance to make it easier for you to see or hear things in the courtroom, or any other accommodation during the Trial?

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* 10. Community in which you reside: (We do not need your actual physical address. Simply let us know what city or community you reside in within Coconino County).

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* 11. Your occupation or occupation prior to retirement:

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* 12. Spouse’s occupation or occupation prior to retirement:

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* 13. Have you ever served on a jury before?

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* 14. The Judicial Assistant is Carrie Faultner. Again, I am Judge Theodore Campagnolo of the Coconino County Superior Court.

Do you know me or anyone on my staff?

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* 15. The Plaintiff is represented by William A. Miller an attorney with the law firm of William A. Miller PLLC.

Do you know Plaintiffs’ attorney or anyone who is associated in any way with his law firm?

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* 16. Would your relationship with them make you unable to be a fair and impartial juror?

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* 17. The Defendants are represented by Doug Tobler, an attorney with the law firm of Hammond & Tobler, P.C.

Do you know Defendants’ attorney or anyone who is associated in any way with his office? 

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* 18. Would your relationship with them make you unable to be a fair and impartial juror?

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* 19. The witnesses who could be called in this case include the following:
  • A.   Harminder Samra
  • B.   Narinder Samra
  • C.   Gurjit Sekhon
  • D.   Michael Wright
  • E.   Umrik Singh
  • F.    Satinder Gill
  • G.   Joga Mann
  • H.   Hoshiar Grewal
Do you know any of the witnesses who could be called in this case?

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* 20. Would your relationship with them render you unable to be a fair and impartial juror?

If you answered “yes” to any of the questions 14-20, please answer the following:

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* 21. Would that familiarity, fact or experience in any way affect your deliberations?

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* 22. Interfere with your ability to follow the instructions of the law that I will give you?

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* 23. Prevent you from fairly and honestly evaluating the evidence presented in this case?

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* 24. Cause you to favor one side or the other?

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* 25. Prevent you from being a fair and impartial juror in this case?

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* 26. Can you set aside your beliefs or opinions, whatever they might be, and not let them affect your consideration of the evidence or application of law in this case?

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* 27. Will you be able to follow the law as given in the jury instructions, disregarding your own notions or ideas about what the law is or ought to be?

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* 28. If selected to sit on the jury this case, would you render a verdict solely on the evidence and testimony presented at trial?

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* 29. In a civil case, a party bringing a claim must prove the claim by a preponderance of the evidence.  Burden of proof means burden of persuasion.  On any claim or defense, the party who has the burden must persuade you, by the evidence, that the claim is more probably true than not true.  This means that the evidence that favors that party outweighs the opposing evidence.  In determining whether a party has met this burden of proof, the jury considers all the evidence that bears on the claim, regardless of which party produced it.  Do you understand and can you follow this instruction?

The attorneys have offered the following statements about the case:

Plaintiff, Harminder Samra, was a member of the two limited liability companies, Holbrook Motel Investors, LLC (“HMI”) and Holbrook Motel Partners, LLC (“HMP”). HMI owned an Econolodge motel in Holbrook, Arizona. Umrik Singh; Satinder Gill; Joga S. Mann; Hoshiar S. Grewal were other members of HMI. HMP owned a Comfort Inn motel in Holbrook, Arizona. Umrik Singh; Satinder Gill; Joga S. Mann; Sukhminder Gill were other members of HMP. Plaintiff claims that the other members of HMI and HMP sold the two companies without her permission, and this caused her damage. Defendants claim that Plaintiff granted them permission, through her husband, to sign the sale documents for her. Defendants also claim that Ms. Samra suffered no damage as a result of the sales.

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* 30. Have you seen, heard or read anything, including on social media of all types, any information about this case?      

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* 31.  Have you, or any members of your family or close friends, ever been involved in any way in a case such as this?

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* 32. Is there anything about the nature of this case that would make it difficult for you to serve as a fair and impartial juror?

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* 33. Jury selection and trial in this case is expected to take approximately four (4) days, excluding jury selection and will occur on:

  •         Friday, October 13, 2023, 8:30 a.m. to 4:30 p.m. (Jury Selection)
  •         Tuesday, October 17, 2023, 8:30 a.m. to 4:30 p.m.
  •         Wednesday, October 18, 2023, 1:30 p.m. to 4:30 p.m.        
  •         Thursday, October 19, 2023, 8:30 a.m. to 4:30 p.m.
  •         Friday, October 20, 2023, 8:30 a.m. to 4:30 p.m.
 After the day of jury selection, except for Wednesday, October 18, 2023, trial will begin each day at 8:30 a.m. and end at 4:30 p.m.  On Wednesday, October 18, 2023, the trial will begin at 1:30 p.m. and end at 4:30 p.m. We will take breaks mid-morning and mid-afternoon.  We will take a lunch break from 12:00 p.m. to 1:30 p.m.  Is there anything about the anticipated length or daily schedule of the trial that presents a problem, whether it be personal, business, or health-related, that is significant enough you feel the need to ask to be excused from service on this jury?

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* 34. Do you work for an employer with five or fewer full-time employees?

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* 35. The law provides that a juror can be excused only if his or her absence from work would "substantially and materially affect the public interest or welfare in an adverse manner”, or if service as a juror would impose an “undue or extreme physical or financial hardship” on you or someone under your care. Would your service on this jury cause such a detriment to the public interest or work such a hardship on you or someone under your care?

By submitting this questionnaire, you affirm that your answers are true.

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