Free Proposed Voir Dire - District Court of Arizona - Arizona

1 mw oFFIcES
BROENING OBERG WOODS & WILSON
2 PROFESSIONAL CORPORATION
1122 EAST JEFFERSON
3 POST OFFICE BOX 20527
PHOENIX, ARIZONA 85036
4 (602) 271-7700
James R. Broening, #004036
5 William R. Phillips, #019949
Attomeys for Defendants
6
7 IN THE UNITED STATES DISTRICT COURT
8 FOR THE DISTRICT OF ARIZONA
9 JERRY SIMMS, a single man, NO.CIV-03-1415 PHX ROS
10 Plaintiff, STIPULATED PROPOSED VOIR
11 DIRE QUESTIONS
vs.
12 STATE FARM FIRE AND CASUALTY
13 COMPANY, an Illinois corporation; ABC
CORPORATIONS I-X; JOHN DOES I—X,
14 Defendants.
15
16 The Plaintiff and Defendant hereby request the following questions on Voir
17 Dire:
18 l. Are you employed:
19 a. [If so], where do you work and what type of work do you do?
20 b. How long have you worked in that position?
21 c. [If the employment has been relatively brief or the person has
22 retired], where did you work before your current position [or
23 before retirement] and what did you do?
24 2. Area within Arizona where you reside.
25 3. Are you married?
26 4. Do you have children?
Case 2:03-cv—01415—ROS Document 141 Filed 11/29/2005 Page 1 of 4

1 5. What are their ages?
2 6. Does anyone in your family work outside the home?
3 a. [If so], where do they work and what type of work do they do?
4 7. How do spend your leisure time activities?
5 8. Have you ever served as a juror before?
6 a. [If so], where and on what type of cases did you serve?
7 b. Did your experience sour you in any way on the judicial
8 system?
9 9. Have you ever brought a lawsuit or been a defendant in a lawsuit?
10 a. [If so], where and on what type of cases were you involved?
ll b. V1/`hat did the case involve?
12 c. Did the case come to a conclusion, and if so, were you
13 satisfied with the result? I
14 10. Have you or a family member ever testified as a witness, either at trial
15 or deposition, in a prior lawsuit? If so, please explain.
16 1 1. Have you or anyone close to you ever been unhappy with the service
17 provided to you by an automobile or homeowners insurance company?
18 12. Have you or any family member been employed by or associated with
19 an insurance company or insurance agency?
20 13. Have you or a family member ever had specific training in insurance,
21 construction or environmental science?
22 14. What is your news source?
23 15. Do you now own any stock in any insurance company? If yes, set
24 forth:
25
26 2
Case 2:03-cv—01415—ROS Document 141 Filed 11/29/2005 Page 2 of 4

1 The name of the insurance company
2 16. Have you ever owned any stock in any insurance company? If yes, please
3 identify the insurance company.
4 17. Do any family members own any stock in any insurance companies? If
5 yes, please set forth the name of the insurance companies.
6 18. Have any family members ever owned any stock in any insurance
7 companies? If yes, please identify any insurance companies.
8 19. Is there anyone here who feels that insurance companies are more often
9 than not victimized by the presentation of fraudulent claims by their insureds?
10 20. Is there anyone here who believes that insurance companies need
11 protection from "frivolous" lawsuits? If yes, please define what you mean by "frivolous"
12 lawsuit.
13 21. How do you feel about "tort reform?"
14 22. Is there anyone here who believes in placing caps on damages against
15 insurance carriers?
16 23. Is there something in your background that will make it difficult for you
17 to sit on this case?
18 24. If you were in the parties' position right now, would you be concemed
19 about having yourself as a juror on this case for any reason whatsoever?
20 25. Do you, for any reason, feel uncomfortable about sitting as a juror on
21 this case?
22
23 / / / E
24
25 / / /
26 3
Case 2:03-cv—01415—ROS Document 141 Filed 11/29/2005 Page 3 of 4

1 DATED this Q iday of November, 2005.
2
3 BROENING OB O S & WILSON, P.C.
4 1
By
5 James R. Broening
William R. Phillips
6 1122 East Jefferson
Post Office Box 20527
7 Phoenix, Arizona 85036
Attorneys for Defendant State Farm Fire and Casualty
8 Campany
9 LAW OFFI ES EPH C. DOLAN 4 ,L awt
m,t·/1 O li g,é<
10 /”’ Op 1/*
of eelh
1 1 By `
Josep C. Do an, E q.
12 1650 N. First Aven e
Phoenix, Arizona 8 003
13 Attomey for Plainti
14
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