1. 0
2. 1
3. 2
4. 3+

1. High School
2. Vocational Degree
3. Bachelors
4. Post Graduate
5. Less than High School
6. High school graduate/GED
7. Some college (but did not graduate)
8. Vocational/technical/associates degree
9. College degree (from a four-year college)
10. Post-graduate degree

1. White Collar
2. Blue Collar
3. Employed Full time
4. Employed Part time
5. Retired
6. A Homemaker
7. Unemployed
8. Self-employed/business owner
9. A full-time student

1. Yes
2. No

1. Yes
2. No

1. Generally Republican / Conservative
2. Generally Democrat / Liberal
3. Generally Independent / Other

First Court is a dispute resolution organization. We help lawyers resolve legal disputes out of court, by showing how real people from the trial area respond to the case.

Are you willing to listen to conflicting evidence and to give us your honest opinion about the disputes in this case?

1. Yes, I am interested in helping to resolve this conflict
2. No, I am not interested in this project (please stop answering)

1. Yes, I am available.
2. No, I am not available (please stop answering)

1. Yes, I agree.
2. No, I do not agree (thanks, but stop answering questions).

Are you comfortable participating in an in-person mock trial with about thirty people with these COVID-19 precautions in place? 

1. Yes
2. Yes, but only if you ______ (explain in the Optional Comments)
3. No

Are you registered to vote in Iowa and/or do you have a Iowa driver's license?

1. Both Iowa driver's license and voter's registration
2. Iowa driver's license
3. Iowa voter's registration
4. NEITHER Iowa voter's registration nor driver's license

What do you consider to be your primary employment status?

1. Employed and currently working
2. Employed and not currently working due to a furlough or similar situation
3. Unemployed, and was UNEMPLOYED before the coronavirus epidemic
4. Unemployed, and was EMPLOYED before the coronavirus epidemic
5. Student
6. Homemaker
7. Retired

1. Yes
2. No

Please describe any and all experience you have participating in legal focus groups, jury research projects, or mock trials. This includes any groups regarding lawsuits where the work you did for them was online or in person.

1. Yes (please explain)
2. No

Have you or anyone close to you ever suffered a serious injury in an accident?

1. Yes, I have suffered a serious accidental injury (please explain)
2. Yes, someone close to me has suffered a serious accidental injury (please explain)
3. No

Have you or anyone close to you ever dealt with car accidents and or serious car-related injuries?

1. Yes, I have (please explain)
2. Yes, someone close to me has (please explain)
3. No, we have not

Would you describe your residence as being located in:

1. An urban neighborhood
2. A suburb
3. A small town (not a suburb)
4. A rural area

1. Management positions
2. Non-management positions

1. Yes, some limits on jury awards sound like a good idea
2. No, I do not favor limits on juries

1. Very conservative
2. Conservative
3. Liberal
4. Very liberal

1. Yes
2. No

Have you or anyone close to you ever hired a lawyer? Sued someone or been sued by someone?

Please describe your experience with lawyers and the legal system.

1. Yes (Please explain)
2. No

Are you involved in any clubs, civic, religious or volunteer organizations? (if so which ones?)

Do you know Jerad Adams, Susan Jones, Tim Mcdern, or Luisa Ruiz?

Do you have any association with Aspen Waste Management, Madam Nails, Timber Delight, or Deli Savor?

1. Yes (explain)
2. No

VOIR DIRE

What is a word or phrase you would use to describe Attorney Don Beattie?

It seems to me that Don used several of his "questions" to make points for his clients, and was not always interested in hearing things from us that didn't support his case.

1. Strongly agree
2. Agree
3. Disagree
4. Strongly disagree

You are in a room filled with difficult people. The group must make some challenging decisions. You need a leader, but you can only choose one of these two lawyers. Which would you choose and why?

1. I would choose the first attorney, Don, because...
2. I would choose the second attorney, Dean, because...

1. I will keep everything I learn as part of this project confidential
2. I will not keep any notes outside of this system
3. I will not keep any other record from this project
4. I will not allow anyone other than myself observe this project
5. I will answer all questions truthfully to the best of my ability
6. I will base my feedback only on what is presented and will not do any outside research about the facts or law of this case

-----PL OPENING-----

Motivation question: According to the family's attorney,  why did this collision take place? What was motivating Aspen Waste Systems?

Why did the family's attorney bring up the words on the cards - fellowship, affection, aid, services etc?

1. To play on our emotions in order to get more money from the jury
2. Because Iowa law requires the jury to evaluate these items
3. Something else, explained below

1X. At this early point in the trial: would you say you are angry or upset with the defendant truck driver and waste company?

1. Yes, very much so
2. Yes
3. No
4. No, not at all

What was the point of the lawyer talking about the compression of time?

1. To help the jury evaluate the past losses experienced by the family
2. To help the jury include in one number all the years these losses will be experienced by the family
3. To comply with the law of damages in the state of Iowa
4. I'm not sure - the lawyer wasn't all that clear about this

What was your reaction to the fact that the truck driver and his friend Mario could not remember what they were talking about when the collision occurred?

1. No big deal - it was a long time ago
2. I don't like this - seems a bit sketchy
3. I really don't like this - they are probably covering up something because this is something most people would rememer

What's the most important thing you heard in the family's Opening?

-----DF OPENING-----

What do you think of the argument that Susan Jones has some legal responsibility for this collision?

1. Strongly agree
2. Agree
3. Disagree
4. Strongly disagree

Susan Jones had risk factors - smoking , diabetes and excess weight - that reduce the number of years the jury should use in calculating the verdict money in this case. Please explain your answer.

1. Strongly agree
2. Agree
3. Disagree
4. Strongly disagree

The use or non-use of the cell phone and the speeding or non-speeding is not relevant in this case. The family's loss is the same and the only reason for telling us these things is to make the jury angry.

1. Strongly agree
2. Agree
3. Disagree
4. Strongly disagree

What's the most important thing you heard in the Defendant's Opening?

What questions do you have? What should the lawyers tell you more about?

1. Yes, I have started or owned a full-time business
2. Yes, someone in my family has started or owned a full-time business
3. No, nobody close to me has started or owned a full-time business

Have you ever worked in a job where you were responsible for compliance or safety?

1. Yes, I have had experience being responsible for safety and/or compliance
2. No, I have NOT had experience being responsible for safety and/or compliance

1. Yes
2. No

1. Yes, I could explain the details of an engine
2. No, I could not explain the details of an engine

1. Yes, most of my work has involved physical labor
2. No, most of my work has not involved physical labor

-----BREAK-----

1X  Did the photographs or exhibits surprise you or teach you anything new about the case?

1. Yes, I learned...
2. No

What is your reaction to Levi Wiley's guilty pleas on the driving violations?

1. Makes me think today's jury should put more fault on either Wiley or Aspen
2. Makes me think today's jury should put more less on either Wiley or Aspen
3. No impact either way.

What is a word or phrase you would use to describe Levi Wiley?

How believable is the testimony of Levi Wiley?  [1= NOT believable at all  -  100= TOTALLY believable]

1. 1
2. 1
3. 100
4. 60
5. 75
6. 15
7. 90
8. 80
9. 15
10. 60
11. 25
12. 30
13. 80
14. 30
15. 77
16. 75
17. 75
18. 75
19. 95
20. 25
21. 20
22. 60
23. 42
24. 25
25. 40
26. 60
27. 50

Please explain your believability rating for Levi. What did he say or how did he move or note any other part of his testimony that caused you to believe or not believe what he was saying.

Levi Wiley's testimony makes me inclined to place

1. more fault on him
2. less fault on him
3. No impact on his fault either way

What questions do you have, or what reactions can you share, concerning the cell phone records? What's important to you?  What do they tell you about the case?

What questions do you have, or what reactions can you share, concerning the GPS system on the rolloff trucks? What's important to you?  What does the GPS system they tell you about the case?

If you could ask the leaders of Aspen Waste one question, what would it be?

Would you say that the leadership of Aspen Waste is hypocritical about the company's cell phone policy for their truckers?

1. Yes, very much so
2. Yes, a little
3. Not really
4. No, not at all

-----PL EVIDENCE PRESENTATIONS-----

Scott Jones.  What is a word or phrase you would use to describe Scott Jones?

Boyd Jones.  What is a word or phrase you would use to describe Boyd Jones?

Josh Jones.  What is a word or phrase you would use to describe Josh Jones?

Ashley Jones. What is a word or phrase you would use to describe Ashley Jones?

The Jones family will feel a lot better after this lawsuit is resolved.

1. Strongly agree
2. Agree
3. Disagree
4. Strongly disagree

Time heals all wounds. The Jones family simply needs to accept this death and move on to live their lives as best they can. Just like all of us have to do.

1. Strongly agree because...
2. Agree because....
3. Disagree because...
4. Strongly disagree because...

What was your reaction to the valuation of Susan's household services at $871,000?

1. Way too high
2. Too high
3. Too low
4. Way too low

If you could ask Scott Jones or any of the Jones children one question, or say one thing to them, what would it be?

-----LUNCH -----

-----DF EVIDENCE PRESENTATIONS-----

Your understanding: what is the main argument of Aspen Waste in this case?

What is a word or phrase you would use to describe Aspen Waste?

1. Strongly agree
2. Agree
3. Disagree
4. Strongly disagree

1. Evidence of driver Wiley's cell phone use while driving
2. Evidence of driver Wiley texting while driving
3. Aspen Waste's Cell Phone use policies
4. Witness statements about how the collision happened
5. Scott Jones's video testimony
6. Susan's Children's video testimony
7. Police citation/driver Wiley's guilty pleas (following too close, speeding)
8. Truck "Black Box" data
9. Aspen Waste having GPS data on its trucks but not using it to monitor speeding

In your own words, what is meant by the burden of proof?  And if you know, how does it apply in this case?  [ok to say, "I don't know"]

-----CLOSINGS AND INDIVIDUAL VERDICTS-----

NEGLIGENCE AND CAUSATION

1. Was Levi Wiley Negligent?
2. If so, was that negligence a cause of the Plaintiff's losses?
3. Was Aspen Waste Systems Negligent?
4. If so, was that negligence a cause of the Plaintiff's losses?
5. Was Susan Jones negligent?
6. If so, was that negligence a cause of the Plaintiff's losses?

How do you allocate fault among the following?

1. Aspen Waste Systems
2. Levi Wiley (truck driver)
3. Susan Jones

What amounts, if any, would fairly compensate plaintiffs in the following categories?

1. Scott Jones, past losses
2. Scott Jones, future losses
3. Boyd Jones, past losses
4. Boyd Jones, future losses
5. Ashley Jones, past losses
6. Ashley Jones, future losses
7. Josh Jones, past losses
8. Josh Jones, future losses

What's the strongest part of the family's case?

What's the strongest part of Levi Wiley & Aspen's case?

What advice do you have for the family lawyers on how they could present the family's case better?

What advice do you have for Aspen's lawyer about how he could present the defendants' case better?

-----SPLIT THE JURORS-----

-----BULLPEN QUESTIONS-----

-----BULLPEN QUESTIONS-----