Free Proposed Jury Instructions - District Court of Delaware - Delaware

Case 1:04-cv-00861-JJF Document 37-3 Filed 05/03/2005 Paget of 3
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
LYNN SAN SOUCIE, )
Plaintiff; g
v. g C.A. NO. O4-0861-JJF
REPRODUCTIVE ASSOCIATES g IURY TRIAL DEMANDED
OF DELAWARE, P.A., )
Defendant. g
DEFENDANT’S PROPOSED VOIR DIRE
Defendant proposes the jury panel be provided with the following written voir dire
questions:
l. The Defendant, Reproductive Associates of Delaware, P.A., is a medical practice
which provides medical care to couples and individuals having difiicultly becoming pregnant
and having children. Reproductive Associates specializes in-vitro fertilization and artificial
H insemination procedures to help infertile couples and individuals achieve pregnancy. In-vitro
fertilization involves the fertilization of an egg and the growth of an embryo outside of the body
under laboratory conditions. Artificial insemination involves the injection of sperm into a
female’s uterus under laboratory conditions. Do you have any beliefs or feelings for or against
these types of procedures which may prevent you from being completely fair and impartial in
this case? I
2. Are you, a relative, or a friend, presently involved in a lawsuit against your
employer or another employer, or have you been involved in such a lawsuit or claim within the
last 5 years? If so, explain the circumstances and the outcome.

Case 1:04-cv-00861-JJF Document 37-3 Filed 05/03/2005 Page 2 of 3
3. Have you, a relative, or a friend ever been involved as a party, witness, or
otherwise, in a situation involving the workplace, or in a case involving a claim for unpaid wages
or overtime compensation? If so, explain the circumstances and the outcome.
4. Have you ever been sued or been involved in a serious dispute with your
employer? If so, explain the circumstances and the outcome.
5. Do you feel that you have been treated unfairly at work or discriminated against
in employment? If so, explain.
6. Are you, a relative, or a friend related to, or personally acquainted with David H.
Williams, Jennifer L. Brierley, Jeffrey Martin, or Keri Morris (formerly Keri Williams), or have
you, a relative, or a friend ever been represented by David H. Williams, Jennifer L. Brierley,
Jeffrey Martin, Kerri Morris, the law firm of Morris, James, Hitchens & Williams LLP, or the
law firm of Margolis Edelstein?
7. Are you, a relative, or a friend, related to, or personally acquainted with any of the
individuals who might appear as witnesses in this case (see attached list)?
MORRIS, JAMES, HITCHENS
& WILLIAMS LLP
O [A / ’ " ’ /
D d H. w1@ ms, Esquire (ID#616)
ennifer L. Brierley, Esquire (]D#407
222 Delaware Avenue, 10m Floor
Wilmington, DE 19801-1621
(302) 888-6800
dys;[email protected]
[email protected]
Attorneys for Defendant
Dated: May 3, 2005
2

Case 1:04-cv-00861-JJF Document 37-3 Filed 05/03/2005 Page 3 of 3
CERTIFICATE OF SERVICE
I, Jennifer L. Brierley, hereby certify that on this 3rd day of May, 2005, I caused
to be served a true and correct copy of Defendant’s Proposed Voir Dire by electronic delivery
and mail to:
Jeffrey K. Martin
Margolis Edelstein
1509 Gilpin Avenue
Wilmington, DE 19806
Attorney for Plaintiff Lynn Sansoucie
r W /
J enngfer L. Brigliy
11.12/016459-0oos/1162756/1 3