Unopposed/opposed motion and brief for use of juror questionnaire (state & fed)

CERTIFICATE OF CONFERENCE

On _______________, 20___, counsel of record for Movant held/attempted a conference with ________________, the attorney for the opposing party regarding the merits of this Motion. Agreement could/could not be reached; therefore, it is presented the Court for a determination.

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UNOPPOSED/OPPOSED MOTION FOR USE OF JUROR QUESTIONNAIRE

AND BRIEF IN SUPPORT OF SAME

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW ____________________ (hereafter “Movant”) and would show this Honorable Court as follows:

As a means to shorten voir dire and provide all parties concerned with more information, Movant proposes that the Jury Questionnaire attached hereto as Exhibit “A” [NOTE: attach proposed questions, such as those in form Trial010] be submitted to each person on the jury panel prior to the starting of voir dire. Movant further requests that no lawyer or party or person called as a witness by any party to this lawsuit shall reveal to the jury, directly or indirectly, who drafted the Juror Questionnaire or who requested that the Court submit the Juror Questionnaire to the potential jurors.

All parties and the Court will benefit from use of the Jury Questionnaire because it will provide all concerned with more information about the jurors in less time. Legal commentators have noted the benefits of using questionnaires.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Movant respectfully...