Preview
1 ERIN HOLBROOK, Chief Counsel
G. MICHAEL HARRINGTON, Deputy Chief Counsel
2 LANDA LOW, Assistant Chief Counsel (SBN 125121)
ROSEMARY LOVE, Deputy Attorney (SBN 25
3 111 Grand Avenue, Suite 11-100, Oakland, CA 94612
Mail: P.O. Box 24325, Oakland, California 94623
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Telephone: (510) 433-9100, Fax: (510) 433-9167
Attorneys for Defendant STATE OF CALIFORNIA,
5
acting by and through the Department of Transportation (“Caltrans”)
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SUPERIOR COURT OF THE STA E OF CALIFORNIA
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COUNTY OF SANTA CLARA
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0
Z HUA HUANG, Individually and as Case No. 19CV346663
successor in interest to WEI LUN HUANG,
deceased; TRINITY HUANG, a minor;
TRISTAN HUANG, a minor; HSI KENG JOINT PROPOSED JURY
HUANG; and CHING FEN HUANG, QUESTIONNAIRE
Plaintiffs,
vs. Complaint Filed: April 2
TESLA INC. dba TES A MOTORS, INC.,
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THE STATE OF CALIFORNIA, andDoes
1 through 100,
7
Defendants.
1
OINT PROPOSED QUESTIONNAIRE
SUPERIORCOURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
CASE NO. 19CV346663
JUROR QUESTIONNAIRE
Full Name: (Please print)
(Last) (First) (Middle Initial)
City or County Residence: Zip Code:
Telephone Numbers:
Home: Work: Cell:
I declare under penalty of perjury that the answers set forth in this Juror Questionnaire are
true and correct to the best of my knowledge and belief. I have not discussed my answers with others
or received assistance in completing the questionnaire.
Signed this day
(Signature)
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INSTRUCTIONS
TO THE PROSPECTIVE JUROR:
The sole purpose of this questionnaire is to aid the Court and the parties in selecting a fair and impartial
jury to try this case. There are no “right” or “wrong” answers to any of the questions. The Court and the attorneys
are just interested in learning about your background an honest opinions. Please take your time to provide
complete and accurate answers.
Only the Court and the legal teams will use the information you give in response to this questionnaire. Your
responses will be treated as confidential The court and all parties will maintain the confidentiality of any information
contained in your responses to the questionnaire.
We do not want to embarrass anyone. This questionnaire is used instead of asking these personal questions in open
court. If you do not understand a question, or your response is private, you may so indicate on the form with a
notation “do not understand” or “private.” The judge and attorneys may ask you those particular questions out of the
presence of the other potential jurors.
Please write your answers in pen and print legibly. If there is not enough room to complete the response, please
continue the response on the last page of the questionnaire, specifying which question you are responding to. Do not
write on the back of the pages.
As a possible juror in this case, it is very important that you preserve the ability to be fair and impartial and to decide
this case solely on the evidence you hear at trial. The Court will instruct you to follow these directions:
Do not read any newspaper or magazine articles, listen to any television or radio broadcasts, or view or listen
to any other information related to this case.
Do not conduct any research or investigation concerning this case such as searching the Internet, reviewing
reference materials, or consulting books or articles.
Do not communicate with anyone about this case, including friends and family members, coworkers
neighbors, or others. This includes discussing the case in person, in writing, by phone or electronic means,
via email, text messaging, or any Internet chat room, blog, website, social media or other feature.
If you are exposed to any information about this case or anything related to it, please turn away immediately.
he law requires these restrictions to ensure that the parties have a fair trial based on the same evidence presented in
court to all the jurors. Please follow them carefully.
You are signing the questionnaire at page 1 under penalty of perjury. Therefore, please make your best effort to give
honest and complete responses. Return your completed questionnaire to the court.
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QUESTIONNAIRE
Full Name: (Please print) ______________________________________
Jury service is essential to the administration of justice. Thus, mere inconvenience will not be
sufficient to excuse a prospective juror. To be excused, a juror must show an unacceptable amount
of personal hardship. In light of these conditions, would service as a juror in this case create
unacceptable hardship for you? YES
If yes, please explain in specific detail:
WHETHER OR NOT YOU ARE CLAIMING HARDSHIP, YOU MUST
COMPLETE THE REST OF THE QUESTIONNAIRE
Do you have any limitations in your ability to read or understand oral or written testimony in
English? YES If yes, please explain:
Do you, or to your knowledge, does anyone close to you, know any of the potential participants in
this trial(See attached Exhibit A)? If yes, please explain:
Please check one: ale Female binary ther PREFER NOT TO
STATE
Place of birth:
Where else have you lived?
ity of residence ___________________________________
What is your racial/ethnic background?
White/Caucasian Black/African American
Hispanic/Latino American Indian or Native American
Asian or South Asian Other (please specify)
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Marital status:
Single and never married Divorced/separated
Currently married Widowed
Living with significant other Other:___________________________
11. Do you have any children or stepchildren? Yes No If “Yes,” please fill in the list below.
Do they live What they do/did at their job (if
Gender Age with you? Education applicable)
Yes
Yes
Yes
Yes
Your highest level of education completed:
Less than high school
High school graduate
Some college: (Major: _____________________
Technical or vocational school: (Type: ___________________
College graduate: (Major: __________________
Post graduate degree: (Major: ______________________
Please list the degrees (if any) you have, the major area of study, and colleges you attended:
Degrees Major and Minor Areas of Study College
If you are married or have a domestic partner, please list his or her occupation.
(If retired or not working, please list his or her usual or former occupation.)
Employer Location Dates (From/To) Position/Type of work/Responsibilities
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Your current employment status (check all that apply):
Employed full time Employed part time
Business owner Homemaker
Self employed Unemployed
Retired i (year) Full time student
Disabled, do not work Work more than one job
Laid off Do not work outside the home
Please list your last three jobs and employers. Describe your work, job duties, and any
management or supervisory responsibilities:
Employer Location Dates (From/To) Position/Type of work/Responsibilities
Have you or someone close to you had any education, training, or experience in the following
areas? (Check all that apply):
Yes, If you checked “Yes” to
Yes, Someone Area of training/education/work any items,
Yourself Close experience please explain
Law, law enforcement, the justice
system, or the courts
Been responsible for enforcing
workplace safety rules and practices
Roadway construction, roadway
design, or maintenance
Traffic management
Public safety
Accident reconstruction or
investigation
Emergency services (EMS, EMT,
etc.)
Engineering
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Psychology or counseling
IT or Tech
AI or machine learning
Electric vehicles
Motor vehicle design,development
or manufacturing
Video game design or development
Have you ever owned and/or managed your own business? YES
If yes, please describe:________________________________________________________
Do you own or rent your current residence? Own Rent Other: ______________________
Do you use any social media platforms? YES NO. If yes, please identify which platforms
you use (e.g., Instagram, Facebook, X (formerly Twitter) etc.):
How often do you play video games? Often Sometimes Never
Do you consider yourself: Conservative Moderate Liberal Other
What areyour main source(s) of news? ______________________________________________
What social, political, civic, charitable, religious, or other organizations are you associated with?
What are your hobbies, interests, and spare time activities? _
What three words would friends and family use to describe you?
1)____________________2)_______________________3)_______________________
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Would friends and family describe you as more of a logical or emotional decision maker?
Logical Emotional Other:______________________________
Would people describe you as an especially cautious or safe driver? Yes
How often do you seek out positions of leadership? Always Often Seldom Never
Please list 3 well known people you admire
Please list 3 well known people you least admire
What is your opinion of large corporations? ________________________________________
What kind of vehicle do you drive? _______________________________________________
Does your vehicle have lane centering technology? Yes Don’t know
Have you eer had any bad experiences with lane centering technology in a vehicle? Yes
If yes, please explain: ____________________________________________________
Does your vehicle have automatic emergency braking technology Yes
Have you ever haany bad experiences with automatic emergency braking
If yes, please explain: ________________________________________
Does your vehicle have cruise control? Yes No
How often do you use cruise control? Often Rarely Never
Have you ever had any bad experiences with cruise control? Yes
If yes, please explain:______________________________________________________
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Have you ever owned a vehicle that did not work as safely as you expected?
YES yes, lease explain: ______________________________________________
Have you read or heard anything about lawsuits involving the safety ofelectric cars
YES If yes, please explain what you have read or heard:
Have you read or heard anythingabout Tesla YES
If yes, please explain what you have read or heard and please identify any media report you can
recall:
Do you have any negative feel ngs about esla? YES NO. If yes, please explain:
Have you or someone close to you ever had any of the following experiences?
Yes, If you checked “Yes” to any
Yes, Someone items,
Yourself Close Experience please explain:
Been seriously injured in an
accident?
Been involved in a serious
automobile accident?
Known someone who was
killed in an accident?
Do you think the automotive industry needs to be more closely regulated?
Yes, definitely Yes, probably Unsure
Opinion of Elon Musk Indifferent/no opinion Negative Positive
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Please explain:_____________________________________________________________
Have you or someone close to you ever worked for a federal, state, municipality, or city
government agency? Yes, me Yes, someone close to me No, never
es:
Who Agency When Work responsibilities
In general, how would you rate the job Caltrans is doing in maintaining safe roadways in Santa
Clara County? Somewhat good Somewhat poorly No opinion
Have you ever had any complaints about work performed by Cal rans? Yes No
If yes, pleaseexplain: ___________________________________________________________
How often do you drive on Highway 101 near the Highway 85 exit ramp located by Mountain
View Very often somewhat often Rarely I have never driven through the area
Do you have a negative opinion of Caltrans? Yes No No opinion
If yes, please explain: __________________________________________________________
From what you have read or heard, do you think jury awards in cases where a person was killed in
an automobile accident are Too high About right Too low No opinion
Do you have any feelings regarding returning a verdict in a large amount of money against
corporation where it is warranted by the law and the facts?
Do you have any feelings regarding returning a verdict in a large amount of money against a public
entity where it is warranted by the law and the facts?
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Have you experienced any significant losses in the past three years, such as death of a loved one
Yes
If Yes: Please explain ___________________________________________________________
To what extent are you still affected by any of these events today
I have coped well and
Still somewhat affected Still greatly affected
adjusted to the situation
During the jury selection process, and f you are chosen to be a juror, the Court will instruct that
you will not be able to blog, tweet, post on Facebook or any other social networks, talk about, or
otherwise communicate anything about this case while the case is pending. Is there any reason
why you cannot follow this instruction? YES
Please explain:_________________________________________________________________
There is a law that says that a corporationor a government entity has to be treated the same as an
individual in court. Do you agree or disagree with that law? Agree Disagree
This is a lawsuit brought by the widow and children of a man who died in a car crash, and the
lawsuit is against Tesla and Cal rans Would you have any difficulty being a fair and impartial
juror in this ca YES Unsure
f yesor unsure , please explain: _______________________________________________
Do you know of any reason you could not be a fair, impartial, unbiased juror in this lawsuit?
YES If yes, please explain: ___________________________________________
Is there anything this questionnaire does not address that you think might be important for the
attorneys and the judge to know YES
If yes, please explain: __________________________________________________________
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SPACE FOR ADDITIONAL RESPONSES. Please include the number of the question for
which you are supplying additional information.
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Preview
1 ERIN HOLBROOK, Chief Counsel G. MICHAEL HARRINGTON, Deputy Chief Counsel 2 LANDA LOW, Assistant Chief Counsel (SBN 125121) ROSEMARY LOVE, Deputy Attorney (SBN 25 3 111 Grand Avenue, Suite 11-100, Oakland, CA 94612 Mail: P.O. Box 24325, Oakland, California 94623 4 Telephone: (510) 433-9100, Fax: (510) 433-9167 Attorneys for Defendant STATE OF CALIFORNIA, 5 acting by and through the Department of Transportation (“Caltrans”) 6 7 SUPERIOR COURT OF THE STA E OF CALIFORNIA 8 COUNTY OF SANTA CLARA 9 0 Z HUA HUANG, Individually and as Case No. 19CV346663 successor in interest to WEI LUN HUANG, deceased; TRINITY HUANG, a minor; TRISTAN HUANG, a minor; HSI KENG JOINT PROPOSED JURY HUANG; and CHING FEN HUANG, QUESTIONNAIRE Plaintiffs, vs. Complaint Filed: April 2 TESLA INC. dba TES A MOTORS, INC., 6 THE STATE OF CALIFORNIA, andDoes 1 through 100, 7 Defendants. 1 OINT PROPOSED QUESTIONNAIRE SUPERIORCOURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA CASE NO. 19CV346663 JUROR QUESTIONNAIRE Full Name: (Please print) (Last) (First) (Middle Initial) City or County Residence: Zip Code: Telephone Numbers: Home: Work: Cell: I declare under penalty of perjury that the answers set forth in this Juror Questionnaire are true and correct to the best of my knowledge and belief. I have not discussed my answers with others or received assistance in completing the questionnaire. Signed this day (Signature) 29403270v1 29481221v1 INSTRUCTIONS TO THE PROSPECTIVE JUROR: The sole purpose of this questionnaire is to aid the Court and the parties in selecting a fair and impartial jury to try this case. There are no “right” or “wrong” answers to any of the questions. The Court and the attorneys are just interested in learning about your background an honest opinions. Please take your time to provide complete and accurate answers. Only the Court and the legal teams will use the information you give in response to this questionnaire. Your responses will be treated as confidential The court and all parties will maintain the confidentiality of any information contained in your responses to the questionnaire. We do not want to embarrass anyone. This questionnaire is used instead of asking these personal questions in open court. If you do not understand a question, or your response is private, you may so indicate on the form with a notation “do not understand” or “private.” The judge and attorneys may ask you those particular questions out of the presence of the other potential jurors. Please write your answers in pen and print legibly. If there is not enough room to complete the response, please continue the response on the last page of the questionnaire, specifying which question you are responding to. Do not write on the back of the pages. As a possible juror in this case, it is very important that you preserve the ability to be fair and impartial and to decide this case solely on the evidence you hear at trial. The Court will instruct you to follow these directions: Do not read any newspaper or magazine articles, listen to any television or radio broadcasts, or view or listen to any other information related to this case. Do not conduct any research or investigation concerning this case such as searching the Internet, reviewing reference materials, or consulting books or articles. Do not communicate with anyone about this case, including friends and family members, coworkers neighbors, or others. This includes discussing the case in person, in writing, by phone or electronic means, via email, text messaging, or any Internet chat room, blog, website, social media or other feature. If you are exposed to any information about this case or anything related to it, please turn away immediately. he law requires these restrictions to ensure that the parties have a fair trial based on the same evidence presented in court to all the jurors. Please follow them carefully. You are signing the questionnaire at page 1 under penalty of perjury. Therefore, please make your best effort to give honest and complete responses. Return your completed questionnaire to the court. 29403270v1 29481221v1 QUESTIONNAIRE Full Name: (Please print) ______________________________________ Jury service is essential to the administration of justice. Thus, mere inconvenience will not be sufficient to excuse a prospective juror. To be excused, a juror must show an unacceptable amount of personal hardship. In light of these conditions, would service as a juror in this case create unacceptable hardship for you? YES If yes, please explain in specific detail: WHETHER OR NOT YOU ARE CLAIMING HARDSHIP, YOU MUST COMPLETE THE REST OF THE QUESTIONNAIRE Do you have any limitations in your ability to read or understand oral or written testimony in English? YES If yes, please explain: Do you, or to your knowledge, does anyone close to you, know any of the potential participants in this trial(See attached Exhibit A)? If yes, please explain: Please check one: ale Female binary ther PREFER NOT TO STATE Place of birth: Where else have you lived? ity of residence ___________________________________ What is your racial/ethnic background? White/Caucasian Black/African American Hispanic/Latino American Indian or Native American Asian or South Asian Other (please specify) 29403270v1 29481221v1 Marital status: Single and never married Divorced/separated Currently married Widowed Living with significant other Other:___________________________ 11. Do you have any children or stepchildren? Yes No If “Yes,” please fill in the list below. Do they live What they do/did at their job (if Gender Age with you? Education applicable) Yes Yes Yes Yes Your highest level of education completed: Less than high school High school graduate Some college: (Major: _____________________ Technical or vocational school: (Type: ___________________ College graduate: (Major: __________________ Post graduate degree: (Major: ______________________ Please list the degrees (if any) you have, the major area of study, and colleges you attended: Degrees Major and Minor Areas of Study College If you are married or have a domestic partner, please list his or her occupation. (If retired or not working, please list his or her usual or former occupation.) Employer Location Dates (From/To) Position/Type of work/Responsibilities 29403270v1 29481221v1 Your current employment status (check all that apply): Employed full time Employed part time Business owner Homemaker Self employed Unemployed Retired i (year) Full time student Disabled, do not work Work more than one job Laid off Do not work outside the home Please list your last three jobs and employers. Describe your work, job duties, and any management or supervisory responsibilities: Employer Location Dates (From/To) Position/Type of work/Responsibilities Have you or someone close to you had any education, training, or experience in the following areas? (Check all that apply): Yes, If you checked “Yes” to Yes, Someone Area of training/education/work any items, Yourself Close experience please explain Law, law enforcement, the justice system, or the courts Been responsible for enforcing workplace safety rules and practices Roadway construction, roadway design, or maintenance Traffic management Public safety Accident reconstruction or investigation Emergency services (EMS, EMT, etc.) Engineering 29403270v1 29481221v1 Psychology or counseling IT or Tech AI or machine learning Electric vehicles Motor vehicle design,development or manufacturing Video game design or development Have you ever owned and/or managed your own business? YES If yes, please describe:________________________________________________________ Do you own or rent your current residence? Own Rent Other: ______________________ Do you use any social media platforms? YES NO. If yes, please identify which platforms you use (e.g., Instagram, Facebook, X (formerly Twitter) etc.): How often do you play video games? Often Sometimes Never Do you consider yourself: Conservative Moderate Liberal Other What areyour main source(s) of news? ______________________________________________ What social, political, civic, charitable, religious, or other organizations are you associated with? What are your hobbies, interests, and spare time activities? _ What three words would friends and family use to describe you? 1)____________________2)_______________________3)_______________________ 29403270v1 29481221v1 Would friends and family describe you as more of a logical or emotional decision maker? Logical Emotional Other:______________________________ Would people describe you as an especially cautious or safe driver? Yes How often do you seek out positions of leadership? Always Often Seldom Never Please list 3 well known people you admire Please list 3 well known people you least admire What is your opinion of large corporations? ________________________________________ What kind of vehicle do you drive? _______________________________________________ Does your vehicle have lane centering technology? Yes Don’t know Have you eer had any bad experiences with lane centering technology in a vehicle? Yes If yes, please explain: ____________________________________________________ Does your vehicle have automatic emergency braking technology Yes Have you ever haany bad experiences with automatic emergency braking If yes, please explain: ________________________________________ Does your vehicle have cruise control? Yes No How often do you use cruise control? Often Rarely Never Have you ever had any bad experiences with cruise control? Yes If yes, please explain:______________________________________________________ 29403270v1 29481221v1 Have you ever owned a vehicle that did not work as safely as you expected? YES yes, lease explain: ______________________________________________ Have you read or heard anything about lawsuits involving the safety ofelectric cars YES If yes, please explain what you have read or heard: Have you read or heard anythingabout Tesla YES If yes, please explain what you have read or heard and please identify any media report you can recall: Do you have any negative feel ngs about esla? YES NO. If yes, please explain: Have you or someone close to you ever had any of the following experiences? Yes, If you checked “Yes” to any Yes, Someone items, Yourself Close Experience please explain: Been seriously injured in an accident? Been involved in a serious automobile accident? Known someone who was killed in an accident? Do you think the automotive industry needs to be more closely regulated? Yes, definitely Yes, probably Unsure Opinion of Elon Musk Indifferent/no opinion Negative Positive 29403270v1 29481221v1 Please explain:_____________________________________________________________ Have you or someone close to you ever worked for a federal, state, municipality, or city government agency? Yes, me Yes, someone close to me No, never es: Who Agency When Work responsibilities In general, how would you rate the job Caltrans is doing in maintaining safe roadways in Santa Clara County? Somewhat good Somewhat poorly No opinion Have you ever had any complaints about work performed by Cal rans? Yes No If yes, pleaseexplain: ___________________________________________________________ How often do you drive on Highway 101 near the Highway 85 exit ramp located by Mountain View Very often somewhat often Rarely I have never driven through the area Do you have a negative opinion of Caltrans? Yes No No opinion If yes, please explain: __________________________________________________________ From what you have read or heard, do you think jury awards in cases where a person was killed in an automobile accident are Too high About right Too low No opinion Do you have any feelings regarding returning a verdict in a large amount of money against corporation where it is warranted by the law and the facts? Do you have any feelings regarding returning a verdict in a large amount of money against a public entity where it is warranted by the law and the facts? 29403270v1 29481221v1 Have you experienced any significant losses in the past three years, such as death of a loved one Yes If Yes: Please explain ___________________________________________________________ To what extent are you still affected by any of these events today I have coped well and Still somewhat affected Still greatly affected adjusted to the situation During the jury selection process, and f you are chosen to be a juror, the Court will instruct that you will not be able to blog, tweet, post on Facebook or any other social networks, talk about, or otherwise communicate anything about this case while the case is pending. Is there any reason why you cannot follow this instruction? YES Please explain:_________________________________________________________________ There is a law that says that a corporationor a government entity has to be treated the same as an individual in court. Do you agree or disagree with that law? Agree Disagree This is a lawsuit brought by the widow and children of a man who died in a car crash, and the lawsuit is against Tesla and Cal rans Would you have any difficulty being a fair and impartial juror in this ca YES Unsure f yesor unsure , please explain: _______________________________________________ Do you know of any reason you could not be a fair, impartial, unbiased juror in this lawsuit? YES If yes, please explain: ___________________________________________ Is there anything this questionnaire does not address that you think might be important for the attorneys and the judge to know YES If yes, please explain: __________________________________________________________ 29403270v1 29481221v1 SPACE FOR ADDITIONAL RESPONSES. Please include the number of the question for which you are supplying additional information. 29403270v1 29481221v1