Free Proposed Voir Dire - District Court of Colorado - Colorado

Case 1:04-cv-01160-LTB-CBS

Document 110

Filed 11/17/2006

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IN THE UNITED STATESDISTRICT COURT FOR THE DISTRICT OF COLORADO 160-LTB-CBS Civil ActionNo. 04-cv-01 ISABELLE D ETKEVORKIAN.
Plaintiff,
V.

INC., d/b/aLIONBRIDGEUS, INC, LIONBRIDGETECHNOLOGIES,
Defendant.

VOIR DIRE QUESTIONS DEFENDANT'SPROPOSED
"Lionbridge"), through its counsel, Inc. (hereinafter DefendantLionbridge Technologies, in The Overton Law Firm, submitsthe following proposedvoir dire questions, no particular order of importance:
l.

If the evidenceshowsthat Lionbridgewas not always asprompt as it would have like to have been about communicating with Ms. Der Kevorkian, can you set aside your reaction to that and determine,basedon the evidence,whether or not Lionbridge breachedany allegedcontract?

2.

Have you ever relied on a companypolicy to obtain a benefit (otherthan health or pensionbenefits)? If so, what were the circumstances?

a

Have you ever sued an employer to enforce a company policy (other than health or pensionbenefits)? If so, what were the circumstances?

Case 1:04-cv-01160-LTB-CBS

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4.

Have you ever complained of wrongful treatmentat work? If so, what were the circumstances?

5. 6.

Have you heard about Lionbridge as a place to work? If so, what have you heard? Have you, your friends or family ever applied for a work visa or for a green card? If so, what were the circumstances?Was the application grantedor denied?

7. 8.

Have you ever performed human resourcesduties at a job? When you are in a job, is it your expectationthat your employer is obligated to put your best interestsaheadof what is best for the business?

9. 10. 11.

the Have you ever been a memberof a union? If so, describe circumstances? Do you have an opinion about unions in the workplace? When you hear an employeeis suing a former employer, do you tend to assumethe employer did somethingwrong?

I2 13

Have you ever been denied a job or a promotion? If so, what were the circumstances? Do you believe that someoneshould be held to a promise no matter what may happen? who madea promiseoff the hook if mattersbeyond their control Would you let someone made it hard to keep the promise? Respectfullysubmitted: November 17, 2006.

THE OVERTONLAW FIRM s/ DanS. Cross Street 1080Kalamath Denver, 80204 CO 303.302.2737 com cross@overtonlawhrm. dan. FORDEFENDANT ATTORNEYS

By:

Case 1:04-cv-01160-LTB-CBS

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Filed 11/17/2006

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CERTIFICATE OF SERVICE The undersigned certifiesthat on November17,2006,a true andcorrectcopyof the foregoing Proposed Voir Dire was electronically filed with the Clerk of Courtusingthe CM/ECF system, which will sendnotificationof suchfiling, andwassentby first-class S. mail, postage U. prepaid, the following: to

JoelC. Maguire, Esq. [email protected] DietzeandDavis,P.C. 2060Broadway, Suite400 Boulder. 80302 CO /s/
BemadetteLopez