Free Proposed Voir Dire - District Court of Arizona - Arizona

1 Sharon S. Moyer No. 013341 [email protected] 2 Mark D. Dillon No. 014393 [email protected] 3 SACKS TIERNEY P.A. 4250 N. Drinkwater Blvd., 4th Floor 4 Scottsdale, AZ 85251-3693 Telephone: (480) 425-2600 5 Attorneys for Defendant 6 7 8 9 Connie Pappas, 10 11 vs.
P.A., ATTORNEYS 4250 NORTH DRINKWATER BOULEVARD FOURTH FLOOR SCOTTSDALE, ARIZONA 85251-3693

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

Plaintiff,

No. CV03 1449 PHX PGR DEFENDANT'S PROPOSED VOIR DIRE

SACKS TIERNEY

12 J.S.B. Holdings, Inc., an Arizona corporation, dba R&D Specialty/Manco, 13 Defendant. 14 15

Pursuant to this Court's May 8, 2006 Trial Order, Defendant requests that the

16 following questions be asked of the prospective jurors: 17 18 19 20 21 22 23 24 25 26 27 28 1. Have you ever felt that you were being bullied by co-workers? 2. Have you ever been the victim of practical jokes in the workplace? 3. Did you ever play practical jokes on others? 4. Have you ever felt that you were being sexually harassed or harassed on the basis of race, ethnicity, age or disability? 5. Have you ever felt that you were discriminated against on the basis of sex, race, ethnicity, age or disability? 6. Did you ever attend any anti-harassment training? 7. Have you ever attended training regarding "hostile working environments?" 8. Were you ever the person in the organization to whom sexual and other types of harassment were reported? 9. Did you ever file a claim of discrimination or harassment with the Equal
614635.01

Case 2:03-cv-01449-PGR

Document 88

Filed 06/12/2006

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P.A., ATTORNEYS 4250 NORTH DRINKWATER BOULEVARD FOURTH FLOOR SCOTTSDALE, ARIZONA 85251-3693

Employment Opportunity Commission or a State Civil Rights Division? 10. Did you ever file a lawsuit against your employer or a former employer? 11. Did you ever experience such a negative work environment that you felt you had to resign? 12. Did you ever feel that you were unfairly criticized for your work performance? 13. Did you ever feel that you did not have the needed skills or training to perform your job? 14. Have you ever experienced stress at work because your job required skills or training that you did not possess? 15. Have you ever worked in an inspection or quality control position? 16. Did you ever work in a machine shop? 17. Have you ever worked in an environment in which you were a minority on the basis of gender, or race, or religion or age? 18. Have you worked in an environment in which the employees were predominantly male? 19. Have you worked in an environment in which the employees were predominantly female? 20. Was it a negative work environment as a result? 21. Are you generally offended by the use profanity? 22. Do your family and friends consider you to be overly sensitive to profanity? 23. Do you ever use profanity? DATED this 12th day of June, 2006. SACKS TIERNEY P.A.

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SACKS TIERNEY

By:

s/ Sharon S. Moyer Sharon S. Moyer

614635.01

Case 2:03-cv-01449-PGR

Document 88 2 Filed 06/12/2006

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 12, 2006, I electronically transmitted the

3 attached document to the Clerk's Office using the CM/ECF System for filing and 4 transmittal of a Notice of Electronic Filing to the following CM/ECF registrant: 5 6 7 8 9 10 11
P.A., ATTORNEYS 4250 NORTH DRINKWATER BOULEVARD FOURTH FLOOR SCOTTSDALE, ARIZONA 85251-3693

David C. Larkin, Esq. DAVID C. LARKIN, P.C. 4645 S. Lakeshore Drive, Suite 6 Tempe, Arizona 85282 William P. Allen, Esq. ALLEN LAW FIRM, LLC 1650 N. First Avenue Phoenix, Arizona 85003 Attorneys for Plaintiff

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614635.01

s/ Sharon S. Moyer Sharon S. Moyer

SACKS TIERNEY

Case 2:03-cv-01449-PGR

Document 88 3 Filed 06/12/2006

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