Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:07-cv-00078-JJF

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Filed 02/04/2008

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE SAMI ALMAKHADHI, Plaintiff, v. DELAWARE PARK, Defendant, ) ) ) ) ) ) ) ) )

Civ. A. No. 07-78-JJF

DEFENDANT'S PROPOSED VOIR DIRE QUESTIONS1

1. Almakhadhi?

Do you know the Plaintiff, Sami Almakhadhi, or his wife, Amatalrahman

2.

Have you, or has anyone close to you, ever been employed by Delaware

Park? If yes, what were your jobs, during what time period, and if you are no longer there, why not?

3.

Do you know any of the lawyers representing the parties in this case,

including Frank Conley, Glenn Brown, Wendy Voss, or Jennifer Wasson? How do you know of him or her?

Delaware Park LLC reserves the right to submit amended voir dire questions as may be required by the Court's rulings on Plaintiff's motion to amend and/or Delaware Park's motion for summary judgment. 1

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4.

Have you, or has anyone close to you, ever been represented by any of the

following law firms: The Conley Firm, Real World Law, P.C., or Potter Anderson & Corroon LLP? If yes, describe the matter or matters in which that firm represented you.

5.

Have you, or has anyone close to you, ever worked for any of the

following law firms: The Conley Firm, Real World Law, P.C., or Potter Anderson & Corroon LLP? If yes, describe the dates you worked there and how your employment ended.

6. Do you know:

There are a number of people who may testify as witnesses in this case.

Sheryl Cartright Nicole Cook Kevin DeLucia Shannon DeLucia Karlyn Dixon Roberta Evans Mir Hadelli Antoinette Hayes Mamun Korashi Holly Lea Yosef Moqbel Nancy Myshko Micki Nardo Judy Passmore Frank Penta Beverly Pope Mary Sue Porter Stacy Suhr Dr. John Townsend Dr. George Bohatiuk How do you know him/her?

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7.

Have you, or has anyone close to you, ever been discriminated or If so, describe the

retaliated against for complaining about discrimination at work? discrimination or retaliation and explain how the situation was resolved.

8.

Have you, or has anyone close to you, ever been harassed based on your

race, national origin, color, or gender by a supervisor at work? If so, describe the harassment and explain how the situation was resolved.

9.

Have you, or has anyone close to you, been a party (plaintiff or defendant)

in a civil lawsuit? If so, please describe the nature and outcome of the suit.

10.

Have you, or has anyone close to you, had an experience with Delaware

Park or at Delaware Park that would cause you to question whether you could be fair to Delaware Park in this case?

11.

Do you have a negative opinion about casinos, horse racing, or gambling

that would cause you to question whether you could be fair to Delaware Park in this case?

12.

Do you have a negative opinion about corporations in general that would

cause you to question whether you could be fair to Delaware Park in this case?

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13.

If the evidence in this case shows that Delaware Park acted in a way you

did not like or did not agree with but did not violate the law, would you have difficulty finding in favor of Delaware Park?

14.

Have you, or has anyone close to you, ever had a chronic physical

condition that prevented you, him or her from working for an extended period of time? If so, what was the nature of the physical problem and how was that situation resolved.

15. from employment ?

Have you, or has anyone close to you, ever been wrongfully terminated

16.

Have you, or has anyone close to you, ever been involuntarily placed on a

leave of absence from work due to a medical condition? If so, describe the circumstances and explain how the situation was resolved.

17.

Have you, or has anyone close to you, ever had work restrictions imposed

by a physician that the employer did not honor? If so, describe the circumstances and explain how the situation was resolved.

18.

Have you, or has anyone close to you, ever worked in excess of work

restrictions imposed by a physician? If so, describe the circumstances and whether the employer was aware that you, he or she had done so.

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19.

At the end of this trial, the Court will instruct you that sympathy cannot

play a part in your decision making. Is there anyone on the panel who will not be able to put aside any sympathetic feelings for a person who is unemployed or has medical problems and reach a determination based on only the facts?

20.

Are you aware of any reason that you could not decide this case in a fair

and impartial manner based on the evidence and according to the law?

POTTER ANDERSON & CORROON LLP

By: /s/ Jennifer C. Wasson Wendy K. Voss (#3142) Jennifer C. Wasson (#4933) Hercules Plaza 6th Floor 1313 N. Market Street P.O. Box 951 Wilmington, DE 19899-0951 (302) 984-6000 [email protected] ­ Email [email protected] - Email Attorneys for Defendant Delaware Park, L.L.C. Dated: February 4, 2008
846204 / 14672-132

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