Free Proposed Voir Dire - District Court of Arizona - Arizona

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Quarles & Brady Streich Lang LLP
Firm State Bar No. 00443100 Renaissance One Two North Central Avenue Phoenix, Arizona 85004-2391
TELEPHONE 602.229.5200

Attorneys for Defendant National RV Holdings Inc. William M. Shattuck (#007727) [email protected] IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Charles DeShazer, Plaintiff, vs. National RV Holdings, Inc., Freightliner Custom Chassis Corporation and Caterpillar Inc. Defendants. NO. CIV-03-0869-PHX-FJM DEFENDANT NATIONAL RV'S PROPOSED VOIR DIRE

Defendant National RV Holdings Inc. ("National RV"), through its undersigned counsel, proposes that the following topics be included in the voir dire examination of the jury: 1. Whether a manufacturer's warranty is an important factor to juror in

deciding to purchase a new motor vehicle. 2. Whether juror owned or leased a motor vehicle that had a recurring

mechanical problem that was difficult to repair or took a long time to repair and if so, a description of the problem and how that problem was resolved. 3. Whether juror owns or has previously owned a motorhome or other

recreational vehicle, and if so: a. The make and model of such motorhome or other recreational vehicle; b. Whether juror has attended a motorhome or recreational vehicle show or rally.

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c.

Whether the motorhome or other recreational vehicle was manufactured by either National RV or Country Coach and if so, whether that fact would make it difficult for juror to be fair and impartial to either the plaintiffs or the defendants in this case.

Whether juror performs his/her own motor vehicle maintenance and repair. Whether juror has purchased an extended or supplemental product warranty,

and juror's related claim history and experience. 6. Juror's understanding of and attitude regarding warranty limitations,

disclaimers or exclusions. 7. Juror's attitude regarding the importance of reading and following an

Owners Manual. 8. Juror's attitude regarding the importance of reading and following the

operating instructions for a product. 9. Juror's warranty claims history and experience regarding: d. e. f. Home; Motor vehicle; and Major appliance.

Whether juror has filed a complaint with the Better Business Bureau or a

similar organization and if so, the product involved, the nature of the complaint and whether the complaint was resolved to the juror's satisfaction. 11. 12. Juror's attitude regarding motorhomes generally. Whether juror has any prior experience or general attitude that may cause a

bias in favor of either the plaintiff or the defendants in this case which involves a claim by the owner of a motorhome that the motorhome he purchased was defective. 13. Juror's employment history: a. As an engineer;

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b. c. d. e. f.

As a law enforcement officer; As an appraiser; At a motor vehicle dealership; As a motor vehicle mechanic; or Within the motor vehicle industry.

Juror's current or past membership or participation in any: a. b. Consumer rights or consumer advocacy organization; or Any motor vehicle club or organization.

Whether juror has been involved in a motor vehicle accident and if so, the

basic details regarding that accident. 16. Whether the juror has ever been a party, a witness or a juror in any lawsuit

of any kind and if so, the details of the juror's status in that litigation and the details regarding the nature and conclusion of that litigation. DATED this 27th day of January, 2006. QUARLES & BRADY STREICH LANG LLP Renaissance One Two North Central Avenue Phoenix, AZ 85004-2391 By s/William M. Shattuck William M. Shattuck Attorneys for Defendants National RV Holdings Inc.

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CERTIFICATE OF SERVICE

I hereby certify that on January 27, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Marshall Meyers, Esq. KROHN & MOSS, LTD. 111 W. Monroe, #711 Phoenix, AZ 85003 Attorneys for Plaintiff John C. Hendricks, Esq. Meagher & Geer P.L.L.P. 8800 North Gainey Center Drive, Suite 261 Scottsdale, AZ 85258 Attorneys for Defendant Freightliner Custom Chassis Corporation

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