Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv-01450-JJF Document 42 Filed 07/10/2006 Page1 of 2 y
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE q
CASSANDRA JOHNSON *
9; ,
Plaintiff, * CIVIL ACTION
* NO. 04-1450 (JJF)
v. *
·k
WAL—MART STORES, INC., *
·}<
Defendant. *
PLAINTIFF'S PROPOSED VOIR DIRE
COMES NOW Plaintiff, pursuant to D.Del.L.R. 47.l(a), and
submits the following proposed questions to be asked of the jurors
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
Plaintiffs, if the evidence and the law so required, or
conversely, to return a verdict in favor of the Defendant if the
V evidence and the law so required?
2. Have you ever been employed by Wal—Mart Stores, Inc. or Sam’s
Club? _
3. Have any of your family members ever been employed by Wal—
Mart Stores, Inc. or Sam’s Club?
4. Are you or any of your family members current or former
stockholders of Wal~Mart Stores, Inc. or Sam’s Club?
5. Have you or any of your family nmmbers ever held any
management positions in any retail store business?
6. Have you or any of your family members ever worked in the

Case 1:04-cv-01450-JJF Document 42 Filed 07/10/2006 Page20f2
Personnel or Human Resources department of any business entity?
7. Have you or any of your family members ever worked in any
business that receives any income from Wa1—Mart Stores, Inc. or
Sam’s Club (e.g., supplier, contractor, by assignment, or
otherwise)?
8. Have you ever been involved in the hiring, promotion,
demotion, termination or discipline of any employee?
9. Have you ever owned your own business or ever been self—
employed?
10. Have you ever been accused of discrimination in the
workplace?
11. Have any of your relatives, friends or colleagues ever been
accused of discrimination in the workplace?
12. Do you think you might trust the testimony of a corporate
officer more than that of an employee who does not have as high a
ranking?
SCHMITT >—»’§ & RODR GUE , P.A.
L ’ avi! ' ‘
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BY: fi U ‘ Z
WJL IAM D. FLE‘ MER, JR. ‘
- Bar I.D. #362
NOEL E. PRIMOS
Bar I.D. #3124
ADAM C. GERBER
Bar I.D. #4653
414 S. State Street
P.O. Box 497
Dover, DE 19903-0497
DATED:'i}1\C%/CM; .Attorneys for Plaintiff