Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:05-cv-00891-SLR

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE : : Plaintiff, : : v. : : : MELLON TRUST OF DELAWARE, : NATIONAL ASSOCIATION, a : Pennsylvania Corporation; MELLON : BANK, NATIONAL ASSOCIATION : (formerly, MELLON BANK (DE) : NATIONAL ASSOCIATION), a : Pennsylvania Corporation; and MELLON : FINANCIAL CORPORATION, a : Pennsylvania Corporation, : : Defendants. LINDA J. BLOZIS,

CIVIL ACTION NO. 05-891 SLR

PLAINTIFF'S AMENDED PROPOSED VOIR DIRE QUESTIONS 1. Are you or any of your close friends or relatives currently or formerly employed by

Mellon Trust of Delaware, National Association; Mellon Bank, National Association; Mellon Bank (DE), National Association; or Mellon Financial Corporation, or any subsidiary, parent, or affiliated company of Mellon Trust of Delaware, National Association; Mellon Bank, National Association; Mellon Bank (DE), National Association; or Mellon Financial Corporation? Yes _________ 2. No ________

Are you, or a family member or close friend related to or personally acquainted with

the plaintiff Linda J. Blozis? Yes ________ No ________

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3.

Are you acquainted with the judge in this case? Yes ________ No ________

4.

Do you have any reason to favor or disfavor attorneys who represent plaintiffs? Yes ________ No ________

5.

Do you have any reason to favor or disfavor attorneys who represent defendants? Yes ________ No ________

6.

Have you or any of your close friends or relatives ever been a plaintiff or a defendant

or any other party in a criminal or civil court proceeding? Yes ________ 7. No ________

Do you have any personal knowledge of this case, or have your read about it

or heard it discussed or have any opinion regarding it? Yes ________ 8. Do you feel you can be a fair and impartial juror? Yes ________ 9. No ________ No ________

Do you have any strong feelings about lawsuits in general? Yes ________ No ________

10.

Do you believe a person who brings a lawsuit should win or lose it? Yes ________ No ________

11.

Do you believe a person who defends a lawsuit should win or lose it? Yes ________ No ________

12.

Do you believe that a lawsuit is not the proper method for resolving disputes? Yes _______ 2 No ________

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13.

Do you know of any other matter which you believe should be called to the Court's

attention as having some bearing on your qualifications or ability to serve as a juror, which you think may prevent you from rendering a fair and impartial verdict based solely on the evidence presented and the Court's instructions as to the law? Yes ________ 14. No ________

Have you or any member of your family ever been a party to any other type of

civil lawsuit as a plaintiff or a defendant, including a small claims suit? Yes ________ 15. No ________

Do you have any strong feelings about the justice system? Yes ________ No ________

16.

Would that experience or feeling affect your ability to fairly and impartially serve

as a juror in this case? Yes ________ 17. No ________

Do you have a special disability or problem that would make it difficult or

impossible for you to serve as a member of the jury in this case? Yes ________ 18. No ________

Do you believe that you have been treated unfairly by an employer because of your

age or sex, or that a spouse, close friend, or relative has been treated unfairly by an employer because of age or sex? Yes__________ No_________

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19.

Do you believe that you have been treated unfairly by an employer because you

complained of age discrimination, or that a spouse, close friend, or relative has been treated unfairly by an employer because he or she complained of age discrimination? Yes__________ 20. No_________

Does any member of the jury believe that he or she could not be fair in deciding a

claim that an employer took adverse employment action against an employee because of the employee's age or sex? Yes__________ 21. No_________

Does any member of the jury believe that he or she could not be fair in deciding a

claim that an employer took adverse employment action against an employee because the employee complained of age discrimination? Yes__________ 22. No_________

Are you, a family member, or close friend related to or personally acquainted with

any of the attorneys in this case: Thomas S. Neuberger, Esquire; John M. LaRosa, Esquire; Stephen J. Neuberger, Esquire; Stephanie Wilson, Esquire; or Thad Bracegirdle, Esquire? Yes__________ No_________

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Case 1:05-cv-00891-SLR

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23.

Does any member of the jury know any of the following witnesses: A. B. C. D. E. F. Brendan Gilmore, Rosemary Thomas, Bill Becker, Gregg Landis, Maria Dunlop, or Linda Blozis? Yes__________ No_________

THE NEUBERGER FIRM, P.A. THOMAS S. NEUBERGER, ESQUIRE (#243) STEPHEN J. NEUBERGER, ESQUIRE (#4440) Two East Seventh Street, Suite 302 Wilmington, DE 19801 (302) 655-0582 [email protected] [email protected]

LAW OFFICE OF JOHN M. LaROSA /s/ John M. LaRosa JOHN M. LaROSA, ESQUIRE (#4275) Two East 7th Street, Suite 302 Wilmington, Delaware 19801-3707 (302) 888-1290 [email protected] Attorneys for Plaintiff Dated: June 4, 2007

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