Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv-00943-KAJ

Document 67

Filed 03/31/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DINO G. PETROCELLI, Plaintiff, vs. DAIMLERCHRYSLER CORPORATION, Defendant. ) ) ) ) ) ) ) ) ) )

Case No. 04-CV-943-KAJ

DEFENDANT DAIMLERCHR YSLER CORPORATION'S AMENDED PROPOSED VOIR DIRE QUESTIONS DaimlerChrysler hereby proposes the following questions for voir dire examination to be propounded by the Court. In addition to the questions listed below, Defendant requests that each juror be asked briefly to describe his/her present job position, how long he/she has been in that position, and any other positions held for substantial periods of time and to provide the same information for his/her spouse. 1. Have you or any of your family or close friends ever been a plaintiff in a lawsuit? a. b. 2. If so, briefly describe the nature of the suit. What was the outcome of the suit?

Have you or any members of your family or any close personal friends ever been involved in any dispute with any employer over discrimination or harassment or a n employment decision such as discipline, promotion, job assignment or termination? a. If so, how was such dispute resolved?

3.

Would the fact that the plaintiff in this lawsuit is an individual and the defendant is a corporation prevent you in any way from fairly considering the evidence and facts presented to you following the Judge's instructions as to the law?

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Case 1:04-cv-00943-KAJ

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Filed 03/31/2006

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4.

Do you believe that merely because the plaintiff has brought a lawsuit that there must be some merit to his claims?

5. 6.

Is there anyone that believes that money is not a motive for a person coming to court? Is there anyone who simply cannot accept the idea that a person could come to court with the primary hope being to collect lots of money?

7.

Have you ever represented yourself in pursuing a claim for money against any company, corporation, or business of any kind?

8.

Would the fact that the plaintiff in this lawsuit is representing himself prevent you in any way from fairly considering the evidence and facts presented to you following the Judge's instructions as to the law?

9.

Is there anyone here who is covered, or has been covered, by a collective bargaining agreement between an employer and a union?

10.

Have you or a member of your family ever raised a concern about a practice of your employer to someone in management at your place of employment? Have you ever raised a concern about an illegal practice of your employer to someone in management at your place of employment? a. If so, please describe.

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Case 1:04-cv-00943-KAJ

Document 67

Filed 03/31/2006

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Respectfully submitted by: POTTER ANDERSON & CORROON LLP By __/s/ Sarah E. DiLuzio__________ Jennifer Gimler Brady (Bar I.D. #2874) Sarah E. DiLuzio (Bar I.D. #4085) Hercules Plaza, 6th Floor 1313 North Market Street Wilmington, DE 19801 Tel: 302-984-6000 Fax: 302-658-1192 and SHOOK HARDY & BACON LLP William C. Martucci, Mo. #28237 Kristen Aggeler Page, Mo. #50852 2555 Grand Blvd. Kansas City, Missouri 64108-2613 Tel: 816-474-6550 Fax: 816-421-5547 Attorneys for DaimlerChrysler Corporation Dated: March 31, 2006

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