Free Proposed Voir Dire - District Court of Colorado - Colorado

Case 1:03-cv-02073-WDM-KLM

Document 200

Filed 12/22/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-02073-WPM-PAC ROBERTA PULSE TONYA HOUSE Plaintiffs, v. THE LARRY H. MILLER GROUP Defendant. _________________________________________________________________ DEFENDANT'S PROPOSED VOIR DIRE _________________________________________________________________ Defendant The Larry H. Miller Group submits the following proposed voir dire: 1. Some individuals may think that workplace discrimination laws go too far. Others think workplace discrimination laws do not go far enough. Do you hold either of those views? If so, which view do you hold and why? 2. Some individuals may think that claims of workplace discrimination are exaggerated. Others think workplace discrimination happens more often than people think. Do you hold either of those views? If so, which view do you hold and why? 3. Have you ever filed a claim or a complaint of any kind against a manager or employer? If so, what was the nature of this complaint? How was it resolved?

Case 1:03-cv-02073-WDM-KLM

Document 200

Filed 12/22/2005

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4. Have you ever experienced what you believe to be discrimination or harassment at your work place? If so, without revealing any uncomfortable details, could you tell me about this experience? How did you respond? 5. Has a close friend or family member of yours ever experienced what they believe to be discrimination or harassment at their work place? If so, without revealing any uncomfortable details, could you tell me what you heard about this person's experience? How did they respond? 6. Have you ever experienced what you believe to be an unfair termination from a job? If so, and without please tell me about this experience? How did you respond? 7. Has a close friend or family member of yours ever experienced what they believe to be an unfair termination from a job? If so, please tell me about this experience? How did that person respond? 8. What would you look for in determining whether an employee's gender discrimination complaint was valid?

Case 1:03-cv-02073-WDM-KLM

Document 200

Filed 12/22/2005

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DATED: December 22, 2005

s/Christopher M. Leh Christopher M. Leh H OLLAND & H ART LLP 1800 Broadway, Suite 300 Boulder, CO 80302 Telephone: 303-473-2700 Fax: 303-473-2720 E-mail: [email protected] Steven M. Gutierrez, H OLLAND & H ART LLP 555 Seventeenth St., Suite 3200 Denver, CO 80202 Telephone: 303-295-8000 Fax: 303-295-8261 E-mail: [email protected] Judith H. Holmes J UDITH H OLMES & A SSOCIATES , LLC 7887 E. Belleview Suite 1100 Englewood, CO 80111 Telephone: 303-228-2267 Facsimile: 303-781-6877 Email: [email protected] ATTORNEYS FOR DEFENDANT

Case 1:03-cv-02073-WDM-KLM

Document 200

Filed 12/22/2005

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CERTIFICATE OF MAILING

I hereby certify that on December 22, 2005, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system that will send notification of such filing to the following e-mail addresses: Kimberlie K. Ryan, [email protected] Judy Holmes, [email protected] Whitney Traylor, [email protected]

s/ Christopher M. Leh