Motion-Secondary: Duda, M.D., Francis J. vs. Baystate Medical Practices, Inc. Formerly Known As Baystate Medical Education and Research Foundation, Inc.

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                                COMMONWEALTH OF MASSACHUSETTS

HAMPDEN COUNTY

Hampden, ss. SUPERIOR COURT Superior Court Department
ELLED of the Trial Court
MAY 25 2018 Civil Action No. 15-679
FRANCIS J. DUDA, M.D., ber ke ,
Plaintiff )
)
vs. ) DEFENDANT’S MOTION AND
) MEMORANDUM OF LAW TO
BAYSTATE MEDICAL PRACTICES, INC., ) REQUEST PANEL VOIR DIRE
fik/a BAYSTATE MEDICAL EDUCATION ) «
AND RESEARCH FOUNDATION, INC. ) & «
Defendant ) om ¢
Defendant, Baystate Medical Practices, Inc. f/k/a Baystate Medical Education and
Research Foundation, Inc. (“BMP”), pursuant to M.G.L. c. 234, § 28, and Superior Court Rule
6(3)(a), requests that its counsel be permitted to conduct panel voir dire regarding the general
topics as set forth herein.
Pursuant to M.G.L. c. 234, § 28 and Superior Court Rule 6(3)(a), BMP requests that its 4
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attorneys be allowed reasonable time to conduct oral examination of the jury venire. M.G.L. c. X
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234, § 28 provides “the court shall permit, upon the request of any party’s attorney or self- 6

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represented party, the party’s attorney or self-represented party to conduct an oral examination of
the prospective jurors at the discretion of the court.” BMP requests to conduct questioning of a
panel of potential jurors on the following general topics:
1. Any juror or a juror’s close family member’s employment with Baystate Health, Inc.,
Baystate Medical Practices, Inc. or Baystate Medical Center, Inc.

2. Any biases toward a large health care provider.

3. Any biases for any reason toward Baystate Medical Center, Inc.

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