Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv-01286-JJF Document 56 Filed 05/O1/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OP DELAWARE
KARI M. (SMITH) PRILLER, *
>l<
Plaintiff, *
>·l=
v_ a
* CA. No 04-1286 (HF)
TOWN OF SMYRNA; DAVID S. *
HUGO, III, individually and in * ‘
his official capacity as Town Manager; *
BEVERLY A. HIRT, individually *
and in her official capacity as * TRIAL BY IURY DEMANDED ¤
Director of the Smyrna Public * ‘
Library; and HARVEY LEGGETT, *
individually and in his official * ‘
capacity as Supervisor of Streetsl * ·
Foreman of Public Works, *
sr r
Defendants *
PLAIN TIFF'S PROPOSED VOIR DIRE I
COMES NOW Plaintiff, pursuant to D.Del.L.R. 47.1(a), and submits the following A
proposed questions to be asked ofthe jurors during voir dire in addition to the Court’s standard
questions.
l. Does any member of the jury panel know of any reason why he or she would be unable
to award money damages in favor of the Plaintiff if the evidence and the law so required, or i
conversely, to retur·n a verdict in favor of`the Defendants if the evidence and the law so required?
2.. Have you or any member of your family ever been employed by the Town of Smyrna? E
3. Have you or any member of your family ever been employed by a municipality?
4. Have you or any member of your· family ever held a management position in any

Case 1:04-cv-01286-JJF Document 56 Filed 05/O1/2006 Page 2 of 3
municipality OI other local government?
5. Have you or any member of your family ever worked in the Personnel or Human
Resources Department ofany governmental or business entity?
6.. Have you or any member of your family ever worked in any business that receives any
income from the Town of Smyrna (eg , supplier, contractor, by assignment, or otherwise)?
7. Do you or any members of your family reside in the Town of` Smyrna?
8.. I-Iave you ever been involved in the hiring, promotion, demotion, termination or discipline
of any employee?
9. Have you ever been accused ofdiscrimination in the workplace?
10.. Have any of your relatives, friends or colleagues ever been accused of discrimination in
the workplace?
ll. Do you think you might trust the testimony of a governmental official more than that of`
an employee who does not have as high a ranking?
SCHMITTINGER & RODRIGUEZ, RA.
sv; M br OL! r
WILLIAM D. FLETCHER, TR. Q
Bm r.r>. #362
NOEL E. Prurvros p

Case 1:04-cv-01286-JJF Document 56 Filed 05/O1/2006 Page 3 of 3
Ba1·I.1D1 #3124
BY: 49/Lo at {;;_,_L_,,/1
ADAM C. GERBER
Ba1iI.D. #4653
414 S1 State Street
P .0.1 Box 497
· _ Dover, DE 19903-0497
DATED: M 6 Attomeys f01·Plai11tiff`