Free Proposed Voir Dire - District Court of Arizona - Arizona

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Jennifer Basola (#23158) KROHN & MOSS, LTD. 5055 Wilshire Blvd., Suite 300 Los Angeles, CA 90036 (323) 988-2400 (866) 431-5575

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA CV 04-0161 PHX ROS LANE SENNETT, Plaintiff, v. WORKHORSE CUSTOM CHASSIS, LLC. Defendants. PLAINTIFF'S PROPOSED VOIR DIRE

1.

What do you do for a living?

2.

Have you or anyone you know ever worked in the automotive or manufacturing industry?

3.

What are your feelings about the Motor Home industry?

4.
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Have you ever owned or leased a Winnebago or any vehicle with a Workhorse chassis?

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Have you ever been in a Motor Home? What was that experience was like?

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6.

Do you have any kind of mechanical background?

7.

Have you ever discovered that something was wrong with a product after you bought it? How long did it take to discover the problem?

8.

If you buy a new product that has a warranty and it was not timely or properly fixed, do you think you should get your money back?

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Have you ever written a letter to a manufacturer or its authorized dealer to complain about a product?

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Do you feel that a consumer is entitled to compensation even if he or she sells a defective product and fully discloses the product's defects?

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Do you own or use a motor home or RV for recreation?

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Do you or a member of your family work in the sales, manufacture or repair of motor homes?

13.

Have you, or a member of your family, ever been involved in a claim or a lawsuit? a) What type of action? When?

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b) c) d)

Were you the plaintiff or the defendant? Was the case resolved to your satisfaction? Was there anything about that experience that would prevent you from being a fair and impartial juror in this case?

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Have any of you experienced any problem or unusual situations with any motor vehicle or motor home that you have owned? a) Which vehicle? Generally describe the circumstances. Would your experience affect your ability to be a fair and impartial juror in this case?

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b) c)

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Have you, or any member of your family, had any unsatisfactory experiences using automobiles or motor homes?

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a) b)

Who was the manufacturer and what was the model of the vehicle? What was the nature of the unsatisfactory experience?

16.

Have you, or a member of your family, ever been employed in a position selling automobiles or motor homes? a) Name of company?

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b) c)

When and where? Is there anything about that employment that would affect your ability to be a fair and impartial juror in this case?

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Have you or any members of your family had training, experience, or employment in the field of law? a) b) c) Who was involved in that activity? What was that involvement? Was there anything about the experience that would affect your ability to be fair and impartial juror in this case?

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Have any of you read or heard anything about manufacturers of automobiles that causes you to have negative opinions about the automotive industry,

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motor home industry or its products? a) b) If so, what is the reason for the negative feelings? Is your feeling so strong that it would prevent you from being fair and impartial in this case? c) Specifically, have you read and or heard anything about Workhorse that causes you to have negative feelings or opinions about Workhorse or its products? If so, reason for negative feelings.

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d)

Is your feeling so strong that it would prevent you from being fair and impartial to Workhorse in this case?

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Workhorse is a corporation, and, under the law, a corporation is considered to be a person. Does anyone have a feeling or belief that a corporation is not entitled to be treated on the same fair and equal basis as an individual in a

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trial?
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RESPECTFULLY SUBMITTED this 25th day of August 2006.

By: s/Jennifer Basola___________ Jennifer Basola KROHN & MOSS, LTD. 5055 Wilshire Blvd., Suite 300 Los Angeles, CA 90036 Attorney for Plaintiff Filed electronically on this 25th day of August 2006, with: United States District Court CM/ECF system Courtesy Copy mailed this 25th day of August 2006, to: Hon Roslyn O. Silver United States District Court, District of Arizona 401 West Washington Phoenix AZ 85003 s/Cathy Bopp Cathy Bopp

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