Jury Selection

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 his career, he has had the opportunity to participate as a trial lawyer in the defense of several prominent criminal cases including two trials involving then Louisiana Governor Edwin Edwards as well as the successful defense of the U.S. Attorney for the Middle District of Louisiana Donald Beckner. He has also litigated several important election challenge cases including representing Senator Mary Landrieu before the United States Senate. Important in Mr. Bickford’s practice has been his representation of Louisiana Political Subdivisions, including Plaquemines Parish and several levee boards and school districts in an effort to remediate, reclaim and restore polluted marsh lands and to lobby for laws that protect the citizens of Louisiana from bearing the burden of the tons of waste left behind by the petroleum industry in our state. Presently, he is representing Plaquemines Parish in their claim against BP as a result of the oil spill in the Gulf. Following Katrina, he was elected co-trial chair of 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 Bayou Corne 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 based workers injured through their exposure to asbestos and other toxins. He was the lead counsel in the first of the Multi-district welding cases to be tried in Cleveland Ohio and presently represents welders in manganese poisoning cases. He has been a long time board member of the Louisiana Association of Justice and also sits on the Board of Governors of the American Association of Justice. He is a member of the St. Thomas More Inn of Court. He has appeared as a legal analyst on the O’Reilly Factor and local New Orleans television stations and continues to teach and 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.

Contact Prior to joining Phelps Dunbar in 1974, Mr. Rosenberg served as a judicial clerk Canal Place to The Honorable Jack M. Gordon, Judge, U.S. District Court, Eastern District 365 Canal Street, Suite 2000 of Louisiana. He also served as the United States Attorney for the Eastern New Orleans, LA 70130 District of Louisiana from 1990 through 1993. Direct: (504) 584-9219 Fax: (504) 568-9130 Mr. Rosenberg is among a select group of lawyers, recognized in the category of [email protected] 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 Service Areas Appellate Litigation Super Lawyers. Commercial Litigation White Collar Defense and Membership / Affiliations Regulatory Investigations • Louisiana State Bar Association; New Orleans Bar Association; Federal Bar Association; American Bar Association Education • National Association of Criminal Defense Lawyers • Tulane University Law School, • Former United States Attorneys Association J.D., 1972; Board of Editors and • Fellow, the American Counsel Association and the Louisiana Bar Editor, Tulane Law Review Foundation • Case Western Reserve University, B.A., 1969 • Admitted: Louisiana: U.S. Courts for the Eastern, Middle and Western

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

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 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.

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.

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

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

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:______

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? ______

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

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

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: ______

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: ______

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

Yes No

If yes, please explain:______

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

Yes No

If yes, please explain:______

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

Yes No

If yes, please explain:______

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) ______

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?

Yes No

If yes, please explain: ______

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

Yes No

If yes, please explain: ______

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?

Yes No

If yes, please explain: ______

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? ______

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. ______

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

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

Yes No

If yes, what is that opinion? ______

61. Have you, a family member or anyone close to you had any association, personal or professional, with Knauf Plasterboard Tianjin?

Yes No

If yes, please explain:______

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

If yes, what is that opinion? ______

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?

Yes No

If yes, please explain:______

67. Have you, a family member or anyone close to you had any association, personal or 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:______

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

Yes No

If yes, what is that opinion? ______

70. Have you, a family member or anyone close to you had any association, personal or professional, with North River Insurance Company?

Yes No

If yes, please explain:______

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:______

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?

Yes No

If yes, please explain:______

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

If yes, what is that opinion? ______

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): ______

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 Thank you for taking the time to fill If you have children or step-children, Have you ever been involved in any type of legal dispute? out this questionnaire. It will save please indicate for each: Yes No time during jury selection. Please (a) age? If yes, were you satisfied with the outcome? answer truthfully, the information (b) currently living at home? Yes No Not resolved yet you provide will be confidential (d) occupation, if any? and only shared with the judge, the Have you or has anyone close to you ever been a victim of XX? court personnel and the trial Yes No teams. Have you or has anyone close to you ever been accused of XX? Name: Yes No EMPLOYMENT Age: What is your current work status? (check How would you describe your religious background? all that apply): Currently Catholic Raised Catholic, not involved now EDUCATION Full-time Part-time Currently Other Raised Protestant, not involved now What is the highest level of education Student Retired No religion Raised with no religion, none now you have completed? (check one) Unemployed Homemaker Less than High School Disabled Have you or has anyone close to you ever been associated in any way with High School Diploma/GED Your current Employer: XX of XX? Some College/No degree Yes, self No Associate’s Degree Please describe your job Yes, someone close Yes, both Bachelor’s Degree duties/responsibilities: Post-grad Degree ______Have you heard of lawsuits against XX such as XX of XX alleging XX of XX? Yes No MARITAL STATUS Current Marital Status: How many people, if any, do you Have you ever heard of the specific case of XX v. XX of XX in which Name Single supervise in your current job? abused XX? Married None 1-10 11-20 20 + Yes No Divorced Separated Spouse’s (or former) current work status Would you have any hesitation about judging XX of XX? Widowed (check all that apply): Yes No Have you ever been married? Not applicable Full-time Yes No Student Retired Would you automatically find against XX of XX without hearing any Unemployed Part-time evidence? Yes No Spouse’s (or former spouse’s) highest Disabled Homemaker level of education completed (check Spouse’s Employer: Do you have any special physical needs, which would make it difficult for one): you to serve as a juror in this case? Yes No Not applicable Less than High School Please describe your spouse’s job The answers I have given are true and correct to the best of my knowledge. High School Diploma/GED duties/responsibilities: ______ Some College/No degree Associate’s Degree Signature Date Bachelor’s Degree Do you know either: Thank you very much for your time answering these questions. Post-grad Degree Name Yes No Name Yes No

1 SUPPLEMENTAL JUROR QUESTIONNAIRE

Thank you for taking the time to fill Spouse’s current employer: out this questionnaire. It will save If you have children or step-children, How long has he/she worked there? time during jury selection. please indicate for each: Please describe his/her job duties/responsibilities: (a) age? Name: (b) currently living at home? (d) occupation, if any? Age: (e) occupation of child’s spouse? 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) EDUCATION Medicine (Health care) [case related] What is the highest level of education Law [case related] you have completed? (check one) [case related] [case related] Less than High School EMPLOYMENT [case related] [case related] High School Diploma/GED What is your current work status? (check [case related] [case related] Some College/No degree all that apply): Associate’s Degree (Major: ) Full-time Part-time If you have checked any above, please describe for each: Bachelor’s Degree(Major: ) Student Retired (a) who is the person (e.g., brother, friend, cousin, etc.) Post-grad Degree(Major: ) Unemployed Homemaker (b) his/her training, education or experience Disabled MARITAL STATUS Current Marital Status: Your current Employer: Single Married Divorced How long have you worked there? Have you ever been involved in any type of legal dispute? Separated Yes No Widowed If yes, were you satisfied with the outcome? Have you ever been married? Please describe your job Yes No Not resolved yet Yes No duties/responsibilities: How long ago was the dispute?

Spouse’s (or former spouse’s) highest Are you, or is anyone close to you, currently involved in a lawsuit? level of education completed (check How many people, if any, do you Witness Plaintiff (filed lawsuit) Defendant (was sued) one): supervise in your current job? No Not applicable None 1-10 11-20 20 + If Yes, please explain the nature of the lawsuit and how it affects you: Less than High School High School Diploma/GED Spouse’s (or former) current work status Some College/No degree (check all that apply): Associate’s Degree (Major: ) Not applicable Full-time Have you or anyone close to you ever had a serious dispute with an Bachelor’s Degree (Major: ) Student Retired employer? Yes No Post-grad Degree(Major: ) Unemployed Part-time If Yes, please explain the dispute: Disabled Homemaker

1 SUPPLEMENTAL JUROR QUESTIONNAIRE

Have you ever heard of any of the following businesses or people? Have you ever heard of [case specific]? Yes No [case related] Yes No [case related] Yes No Have you or anyone close to you ever had experience with [case specific]? [case related] Yes No Yes No [case related] Yes No If yes, what was the experience? [case related] Yes No [case related] Yes No [case related] Yes No [case related] Yes No [case specific] True False [case related] Yes No [case related] Yes No [case specific] True False

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

Have you or anyone close to you ever [Case Specific]? Yes No This trial is expected to last __ weeks. Do you have any specific problems at If yes, [Case Specific]? 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:

If yes, did you (or they) ever [Case Specific]? Yes No Do you have any special physical needs, which would make it difficult for If yes, please explain. If no, please explain why not. 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, Have you or anyone close to you ever been involved in a dispute over [Case please explain below: Specific]? Yes No If yes, please explain?

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.

2 1

Visual Verbal Non-Verbal

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

UC1 6/10 2

Teach Charm

Move PoorPoor CommunicationCommunication isis ResponsibleResponsible ff or: or:

65% 80% 90% Children’s Emotional Marital Problems Job Discontent 80%80% ofof allall 90%90% ofof Problemsjobjob 90%90% ofof jobjob maritalmarital discontentdiscontent inability/inability/ problemsproblems dysfunctiondysfunction 4

“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

Mastering Charm 5

Mastering Charm 6

Mastering Charm IMAGE: Inaccurate Feedback 7

Mastering Charm IMAGE: Inaccurate Feedback 8

Mastering Charm IMAGE: Vested in our own image 9

Mastering Charm IMAGE: Vested in our own image 10

Mastering Charm IMAGE: Vested in our own image

Facial Expressions

Mastering Charm IMAGE: Unmanaged non - verbal behavior

P o s t u r e

Mastering Charm IMAGE: Unmanaged non - verbal behavior

S p a c e

Mastering Charm IMAGE: Unmanaged non - verbal behavior

G e s t u r e s

Mastering Charm IMAGE: Unmanaged non - verbal behavior

G e s t u r e s

Mastering Charm IMAGE: Unmanaged non - verbal behavior

S c e n t

A r t i f a c t s

Mastering Charm IMAGE: Unmanaged non - verbal behavior 17

Mastering Charm IMAGE: Perspective 18

Mastering Charm

Be Likeable! 19 20 Theory of Reciprocity

Ten Ways to Be More Likeable

Mastering Charm Likability - 1 21

Mastering Charm H u m o r - 2 22

Mastering Charm A f f e c t i o n - 3 » 23 Affection

Healthiest Women Healthiest Men

» Affectionate » Those who defend own » Sympathetic beliefs » Sensitive to needs of others » Independent » Understanding » Assertive » Compassionate » Forceful » Eager to soothe hurt feelings » Have leadership abilities » Warm » Dominant » Tender » Aggressive » Love children » Gentle

Mastering Charm A f f e c t i o n - 3 24

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

Mastering Charm E m p a t h y - 4 25

“The supreme accomplishment is to blur the line between work and play.”

- Arnold Joseph Toynbee, Philosopher

Mastering Charm Like what you do - 5 26

Mastering Charm Be generous - 6 27

Mastering Charm Self disclosure - 7 28

Mastering Charm To u c h - 8 29

Mastering Charm M i r r o r i n g - 9 30

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

- Stephen Covey

Mastering Charm I n t e r e s t [ ing] - 10 » 31 Interest[ing] Needs to Cross Gender

Women Men

» Get information » Give information

» Connect with others » Set goals

» Talk about people » Talk about things

» Share feelings and » Share facts, not details details » Solve problems » Build relationships

Mastering Charm I n t e r e s t [ ing] - 10 32 Success is Attributable To:

7% - Information, Intelligence, or Skill

93% Attitude

Source: Harvard Business School Study 33 34

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