Free Proposed Voir Dire - District Court of Colorado - Colorado

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

Document 106

Filed 11/17/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-01160-LTB-CBS ISABELLE DerKEVORKIAN, Plaintiff, v. LIONBRIDGE TECHNOLOGIES, INC., d/b/a LIONBRIDGE US, INC., SHARRYN E. ROSS and ROSS, MARTEL & SILVERMAN, LLP Defendants. ______________________________________________________________________________ PLAINTIFF'S PROPOSED VOIR DIRE QUESTIONS ______________________________________________________________________________ Plaintiff, by her attorneys, Dietze and Davis, P.C., respectfully submits the following proposed voir dire questions for the Court's consideration. 1. This case relates to a dispute arising from an employment relationship. Been involved in a dispute with an employer? With an employee? What were the circumstances? Anything about your viewpoint or past experience that would hinder your ability to be a fair and impartial juror? Held a position of management? What position, responsibilities? Dealt with or have knowledge of an immigration issue involving yourself or another person? Circumstances? Isabelle DerKevorkian is a citizen of France who was working for an American country under a work Visa and was attempting to obtain a green card to remain and work in the United States. Does anyone have views on immigration that would hinder your ability to be a fair and impartial juror? Isabelle DerKevorkian is a citizen of France who was working for an American country under a work Visa and was attempting to obtain a green card to remain and work in the United States. Does anyone believe that foreigners should not be able to legally work in the United States under a Visa or green card?

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

Document 106

Filed 11/17/2006

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Isabelle DerKevorkian is a citizen of France who has brought a lawsuit in our court against an American company. Does anyone believe that a citizen of a foreign country should not be able to sue in our courts? Isabelle DerKevorkian is a citizen of France. Does anyone believe that French citizens do not deserve equal treatment in our courts either because they are foreigners or because some people believe that France has not supported the United States government in certain foreign policy matters? Been involved as a party in litigation? Circumstances? Been involved in a contract dispute? Circumstances? Is there anything about your viewpoint or past experience that the Court needs to know or that you should volunteer in order to help the Court determine whether you can be an unbiased juror?

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Dated this 17th day of November, 2006. Respectfully submitted, DIETZE and DAVIS, P.C. By: "s/ Joel C. Maguire" Joel C. Maguire Dietze and Davis, P.C. 2060 Broadway, Suite 400 Boulder, CO 80302 Telephone: (303) 447-1375 Fax: (303) 440-9036 Email: [email protected] Attorney for Plaintiff Isabelle DerKevorkian

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

Document 106

Filed 11/17/2006

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CERTIFICATE OF SERVICE I hereby certify that on November 17, 2006, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: John Edwin Bolmer, II [email protected] [email protected] Dan S. Cross [email protected] [email protected] David Everett Leavenworth, Jr. [email protected] [email protected] [email protected]

By: "s/ Susan J. Armour" Susan J. Armour, Legal Assistant Dietze and Davis, P.C. 2060 Broadway, Suite 400 Boulder, CO 80302 Telephone: (303) 447-1375 Fax: (303) 440-9036 Email: [email protected]

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