Free Proposed Voir Dire - District Court of Arizona - Arizona

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David C. Larkin #006644 DAVID C. LARKIN, P.C. 4645 South Lakeshore Drive, Suite 6 Tempe, Arizona 85282 Telephone (480) 491-2900 Fax (480) 755-4825 William P. Allen #011161 ALLEN LAW FIRM, LLC 1650 North First Avenue Phoenix, Arizona 85003 Telephone (602) 495-6502 Fax (602) 277-9839 Attorneys for Plaintiff

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Connie B. Pappas, Plaintiff, vs. J.S.B. Holdings, Inc., d.b.a. R&D Specialty/Manco, Defendant. Plaintiff Connie Pappas provides the following voir dire questions: Dated this 12th day of June, 2006. DAVID C. LARKIN, P.C. By: /s David C. Larkin David C. Larkin and ALLEN LAW FIRM, LLC By: /s William P. Allen William P. Allen Attorneys for Plaintiff No. CV-03-1449-PHX-PGR PLAINTIFF' PROPOSED VOIR DIRE QUESTIONS

Case 2:03-cv-01449-PGR

Document 90

Filed 06/12/2006

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Electronic notice and service of documents provided to: Sharon S. Moyer No. 013341 Mark D. Dillon No. 014393 SACKS TIERNEY P.A. 4250 N. Drinkwater Blvd., 4th Floor Scottsdale, AZ 85251-3693 Attorneys for Defendants /s David C. Larkin

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Case 2:03-cv-01449-PGR

Document 90

Filed 06/12/2006

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PLAINTIFF'S VOIR DIRE QUESTIONS

What is the highest level of education you have completed? Have any of you gone to law school or taken legal courses? How long with current employer. (If less than ten years, list prior employers

to cover the past ten years of employment.) 4. 5. 6. Are you married? What is the identity of other individuals, if any, who live with you. What are the occupation(s) of your spouse (or "significant other") and any

adult children? How long has each been employed with their current employer? 7. Have you or a member of your immediate family ever owned a business? a. If so, state the name of the entity, the type of business, number of employees. Was the business ever sued? Was the business ever sued by an

In general, what was any lawsuit about? What was the outcome of the lawsuit(s)?

What community or professional organizations are you currently active in? Which publications do you read on a regular basis? (Magazines and

Have any of you or any of your relatives ever been a party in a lawsuit, either

as plaintiff or defendant? (If yes, describe each lawsuit, including outcome.) 11. Have any of you ever served on a jury before. (If so, state whether it was civil

or criminal, the basic facts, and what the jury decided.)

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12.

This trial is expected to last four workdays. Do any of you have any reason

why you could not serve on a trial that would last that long? Would any of you suffer financial hardship if you were required to serve on a jury this week? Do any of you feel that you might tend develop strong feelings against one side or the other if that side's presentation of evidence seemed to take too long to you? 13. Do any of you have any physical or mental disability or illness that would

make it difficult for you to hear or understand the testimony and evidence that will be presented? Are any of you on medication, or do you expect to be on medication, which might affect your ability to be a juror in this case? Do any of you have any problems that might make it difficult for you to remember the testimony that is presented? 14. Do any of you know anything about the lawyers or law firms involved in this

case which has caused you to form an opinion about those lawyers or law firms? 15. Based on what we have said so far, do any of you believe you know anything

about this case? 16. Have you, or has anyone you know, ever been an employee who worked in a

quality control department or a machine shop? 17. Please describe all of the jobs or positions you have had in the last five years,

and tell us a little bit about your responsibilities in each position. 18. 19. 20. 21. Have you ever supervised any employees? Have you been responsible for hiring or firing employees? Has any employee you supervised filed a complaint against you? Have any of you had unpleasant experiences at work involving coworkers that

you reported to management? (If so, please describe)

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22.

Have any of you ever thought about taking any form of legal action against any

of your employers or co-workers? (If so, describe why this was considered.) 23. Do you have any close friends or family members who have thought about

bringing legal action against their employer or co-workers? (If so, describe the nature of the dispute, whether suit was tried and the outcome.) 24. Have any of you (or any of your close friends or family members) ever filed

a claim charging discrimination against your employers or co-workers? (If so, please give details and the outcome.) 25. Are any of you familiar with the functions of the offices of the Equal

Employment Opportunity Commission or the Arizona Civil Rights Division? (please describe what you know about those offices and how you came to learn about them.) 26. Have any of you or a member of your family ever filed a charge of sex

discrimination with the EEOC? 27. This case is about Mrs. Pappas's claim that she was harassed by male co-

workers at work because she was a woman, and that because her employer failed to stop the harassment she was forced to quit her job. Have any of you or a member of your family or any close personal friends ever experienced anything at work that you considered to be sex discrimination or harassment because of sex. (For any affirmative responses, please describe the circumstances, any action taken and the outcome.) 28. Has anyone ever accused you or a member of your family or a close personal

friend of workplace harassment? (If any affirmative, describe.) 29. Do any of you have jobs that require you to take reports of, or investigate,

claims of discrimination? (If any affirmative, describe.)

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30.

Even if it is not part of your usual job duties, have any of you ever been

involved (in any way) in an investigation regarding a complaint about something in the workplace, either as a witness, or a supervisor who received a complaint about someone else, or anything of that nature? (If affirmative, describe the circumstances, any action taken and the outcome.) 31. Have any of you received any training about unlawful discrimination or

harassment laws? Have you read anything about these topics? 32. Has anyone ever accused you or a member of your family or a close personal

friend of discrimination or harassment, whether the claim was meritorious or not? (If any affirmative, describe.) 33. Do any of you have jobs that require you to take reports of, or investigate,

claims of harassment or discrimination? (If any affirmative, describe.) 34. Even if it is not part of your usual job duties, have any of you ever been

involved (in any way) in an investigation regarding a complaint about something in the workplace, either as a witness, or a supervisor who received a complaint about someone else, or anything of that nature? (If affirmative, describe the circumstances, any action taken and the outcome.) 35. Would any of you give greater weight to a statement by an employer simply

because it was made by the employer? 36. 37. describe.) Have any of you ever been convicted of a criminal offense? Do any of you have strong feelings about the courts or jury system? (If so,

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38.

Based on what you have heard so far, have any of you formed a judgment

about the merits of Mrs. Pappas's claim or the defendant's defenses? (If so, ask juror to explain privately.) 39. Have any of you or a member of your family ever worked in the field of human

resources or personnel relations? In what capacity? 40. Do you or any member of your family have any special knowledge about

personnel policies or human resources management? 41. Is there any reason why you tend to believe a supervisor or manager over a

subordinate employee simply because of his or her position? 42. 43. Have you or anyone in your family studied or taken any courses in law? Do you believe one sex is generally more truthful than the other? If, so, which

44. 45.

Would any of you prefer to have a male supervisor? A female supervisor? Do you think it is appropriate to question prospective jurors as we are doing

here today? Why or why not? 46. Have you seen or read anything in the news media about proposals for

reforming our justice system, for example tort reform? What have you read or heard? How do you feel about that? 47. Do you feel the Courts are clogged by frivolous lawsuits? If so, do you think

it is people who make the claim who cause these frivolous lawsuits or is it the lawyer's doing? Why? What do you think would help the problem? 48. Do you have any experiences involving discrimination or harassment that

would affect your ability to be fair and impartial in this case? If so, please explain.

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