Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:07-cv—00129-IVIPT Document 65 Filed 08/18/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SHANNON A. LAYMON, ; C.A. No. 07—l29 MPT
Plaintiff, * `
v. i

LOBBY HOUSE, INC., *
a Delaware corporation, *

Defendant. *
JOINT PROPOSED VOIR DIRE g
COME NOW the parties, pursuant to D. Del. L.R. 47.1 (a), and
submit the following proposed questions to be asked of the jurors
n during voir dire in addition to the Court’s standard questions.
l. Does any member of the jury panel know of any reason why
he or she would be unable to award money damages in favor of the
Plaintiff, if the evidence and the law so required, or conversely,
to return a verdict in favor of the Defendants if the evidence and
the law so required?
2. Have you. or any· of your family· members ever been
employed by Lobby House, Inc.?
3. Have you ever been a customer at The Lobby House?
4. Have you or any of your family members ever held any
management positions in any restaurant/bar businesses?
5. Have ·you. or any· of your family· members ever been
terminated from a restaurant/bar business?
6. Have you or any of your family members ever worked in
any business that receives any income from Lobby House, Inc.
(e.g., supplier, contractor, by assignment, or otherwise)?

Case 1:07-cv—00129-IVIPT Document 65 Filed 08/18/2008 Page 2 of 3
7. Have you ever been involved in the hiring, promotion,
demotion, termination or discipline of any employee?
8. Have you ever owned your own business or ever been self-
employed?
9. Have you or any of your relatives or friends ever been
accused of discrimination in the workplace?
10. Do you think you might trust the testimony· of a
management—level employee more than that of an employee who does
not have as high a ranking?
11. Have you. or any' of your family· members ever` been
terminated from a restaurant/bar business?
12. Have you or any of your family members ever been
sexually harassed?
13. Have you or any of your family members ever been subject
to a hostile work environment?
14. Have you or any' of your family· members ever` been
wrongfully terminated from employment?
15. Have you or any of your family members ever been subject
to discrimination in the workplace?
16. Have you or any of your family members ever been subject
to harassment in the workplace? `
17. Have you or any of your family members ever been subject
to retaliation in the workplace?
18. Do you or any of your friends or family members know
Shannon Laymon? _
19. Have you or any of your family members ever filed a
charge of discrimination?

Case 1 :07-cv-00129-IVIPT Document 65 Filed 08/18/2008 Page 3 of 3
20. Have you or any of your family members ever been
employed at a restaurant/bar business? `
SCHMITTINGER AND RODRIGUEZ, P.A. YOUNG, MALMBERG & HOWARD
BY: gs; Noel E. Primos BY: [sg Ronald G. Poliguin
NOEL E. PRIMOS, ESQUIRE RONALD G. POLIQUIN, ESQUIRE
Bar I.D. #3124 Bar I.D. #4447
414 South State Street 30 The Green
P.O. Box 497 Dover, Delaware 19901
Dover, Delaware 19903-0497 (302) 672-5600
(302) 674-0140 Attorney for Defendant
Attorney for Plaintiff

Case 1:07-cv—00129-IVIPT Document 65-2 Filed 08/18/2008 Page 1 of 1
CERTIFICATE OF SERVICE
I hereby certify that I have caused copies of the fo11owing:
JOINT PROPOSED VOIR DIRE
to be served upon:
Ronald G. Poliquin, Esquire
Young Ma1mberg & Howard, P.A.
30 The Green
Dover, DE 19901
_ www IY I
via electronic service on 6¤1y* , 2008.
SCHMITTI R &» RO RIGUEZ, P.A.
BY: / , "*·‘“’“"
NOE E. PRIMOS
Bar I.D. # 3124
414 S. State Street
P.0. Box 497
Dover, DE 19903
(302) 674-0140
Attorney for Plaintiff