Free Voir Dire Questions - District Court of Delaware - Delaware

. Qase 1 :05-cv—OO284-GIVIS Document 91 /I;/|@@__j§~£§?O5/2007 ;;)P@g`ej1 <@§gc4_,{CI"
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IN THE UNITED STATES DISTRICT COURT
F OR THE DISTRICT OF DELAWARE
SARA S. ECHEVARRIA, )
)
V Plaintiff )
)
v. ) Civil Action No. 05-284 (GMS)
)
U-HAUL INTERNATIONAL, INC., )
ROGER MAYFIELD, and NATIONWIDE )
GENERAL INSURANCE COMPANY, )
)
Defendants. )
Vom Dum
. Good morning, ladies and gentlemen, I am about to ask you a series of questions that we
call voir dire. The purpose of the voir dire examination is:
(a) to enable the court to determine whether or not any prospective juror should be
excused for cause;
(b) to enable counsel for the parties to exercise their individual judgment with respect
to peremptory challenges -- that is, challenges for which counsel need not give a
reason.
• Staff introduced.
• Panel sworn.
If any of you would answer "yes" to any of these questions, I would ask you to stand up
and, upon being recognized by me, to state your number. At the end of the questions, I
will ask those who have responded "yes" to any of the questions to come to sidebar (that
is, up to the bench next to me) with counsel for the parties to discuss your answers.
This case is expected to take 5 days to try. The schedule that I expect to maintain over
those 5 days will be as follows:
We will nonnally begin the day at 9:00 a.m promptly. We will go until 1:00 p.m. and,
after a one hour break for lunch, from 2:00 p.m. to 4:30 p.m. There will be a fifteen

. Case 1 :05-cv-00284-GIVIS Document 91 Filed 03/05/2007 Page 2 of 3
minute break at 11:00 a.m. and another fifteen minute break at 3:15 p.m. One exception
to this schedule may occur when the case is submitted to those of you who are selected to
serve as jurors for your deliberation. On that day, the proceedings might last beyond 4:30
p.m. We will post a copy of this schedule for the jury’s convenience in the jury
deliberation room.
1. Does the length of this trial or the schedule contemplated by the court present a special
problem to any member of the panel?
DEscRn>rroN or run C/xsr;
This case is an action for negligence. The plaintiff in this case is Sara Smith, formerly
known as Sara Echevania. The defendants in this case are Roger Mayfield, Nationwide
General Insurance Company (or simply, Nationwide) and U—Haul Company of Florida (or
simply, U-Haul). For those of you selected to serve as jurors, I will give you more
detailed instructions regarding the meaning of the word negligence once you are swom-in
as jurors and again at the conclusion of the trial. For now, I will simply tell you that Ms. _
Smith is accusing the defendants of negligence arising out of a collision that occurred on
May 15, 2004 between the vehicle she was operating and a U-Haul trailer being towed by
Mr. Mayfield which broke free Hom its hitch on Route 2 near the intersection of Upper
Pike Creek Road in Newark, De. Ms. Smith seeks damages for this alleged negligence.
The defendants deny that their negligence caused the collision.
2. Has any member of the panel heard or read anything about this case?
3. Have you or any member of your immediate family (spouse, child, parent or sibling) ever
been employed by the defendant Nationwide, or other insurance company, or the
defendant U-Haul, or other leasing company?
4. Have you or any member of your immediate family ever owned stock in either of these
companies?
5. Have you or any member of your immediate family ever had a business relationship of
any kind with either of these companies?
6. Have you or any member of your immediate fa.mily had any negative or positive
experience with the products of either of these companies?
• Counsel will be asked to introduce themselves, their firms, etc.
7. Does any member of the panel, or your immediate family, know any of the attomeys
involved in the case or have you or any of your immediate family had any business
dealings with or been employed by any of these attomeys or their respective law firms?

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• Counsel will be asked to read names of potential witnesses.
8. Does any member of the panel know or is any member of the panel familiar with any of
the prospective witnesses?
9. Have you ever served as a juror in a criminal or a civil case or as a member of a grand
jury in either a federal or state court?
10. Have you or has anyone in your immediate family ever participated in a lawsuit as a party
or in any other capacity (such as a plaintiff, defendant, or witness)?
11. If you are selected to sit on this case, will you be able to render a verdict solely on the
evidence presented at the trial and in the context of the law as I will give it to you in my
instructions, disregarding any other ideas, notions, or beliefs about the law you may have
or that you may have encountered in reaching your verdict?
12. Is there any member of the panel who has any special disability or problem that would
make serving as a member of the jury difficult or impossible?
13. Having heard the questions put to you by the court, does any other reason suggest itself to
you as to why you could not sit on this jury and render a fair verdict based on the
evidence presented to you and in the context of the court’s instructions to you on the law?