Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1:04-cv—00414-SLR Document 111 Filed 07/22/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT -
IN AND FOR THE DISTRICT OF DELAWARE
WILLIE DAVIS, JR., NATHANIEL BRIDDELL, ) _
GEORGE W. FEDDIMAN, JOSEPH GARRISON, ) C. A. NO. 04-0414-SLR `
LARRY E. GIBBS and ROY H. WALTERS, ) .
) J URY TRIAL DEMANDED
ALL SIMILARLY-SITUATED CURRENT AND )_
FORMER EMLOYEES OF MOUNTAIRE ) COLLECTIVE ACTION
- FARMS, INC., MOUNTAIRE FARMS OF ) .
DELMARVA, INC., and MOUNTAIRE FARMS )
OF DELAWARE, INC., )
‘ J
` Plaintiffs, )
_ )
. V- )
- )
MOUNTAIRE FARMS, INC., )
MOUNTAIRE FARMS OF DELMARVA, INC., )
and MOUNTAIRE FARMS OF ) i
DELAWARE, INC., all Delaware corporations, ) .
) .
Defendants. ) U
PLAINTIFFS’ PROPOSED VOIR DIRE TO JURY PANEL g
Good morning, ladies and gentlemen. I am Judge Robinson, and I will be presiding over
the trial for which a jury is about to be drawn in the case captioned Davis v. Mountaire Farms.
Briefly stated, this case is a civil action brought by plaintiff(s) Willie Davis, Jr., Nathaniel -
Briddell, Joseph Garrison, Larry E. Gibbs and Roy I-I. Walters against the Defendant Mountaire _
Farms of Delmarva, Inc. J
The trial is expected to last from ; our trial days will run l 4
approximately from am. to p.m.
Plaintiffs are represented by Jeffrey K. Martin, an attorney with Martin & Wilson.
Defendants are represented by Arthur Brewer and Eric Hennnendinger, attorneys with Shawe &
Rosenthal. With them is Matthew Boyer, of Connelly, Bove, Lodge & Hutz. I
I I

Case 1:04-cv—00414-SLR Document 111 Filed 07/22/2008 Page 2 of 3
In light of this brief summary, I will ask the panel certain questions, the purpose of which
. is to: (1) enable the Court to determine whether or not any prospective jurors should be excused
for cause; and (2) enable counsel for the parties to exercise their individual judgment with
respect to peremptory challenges, that is, challenges for which no reason need be given by
counsel. If any of you- answer any question "yes," please stand up and, upon being recognized
by the Court, state your juror number. When I have concluded asking all the questions, we will
`call you to the bench individually to speak with you about your affirmative response or
responses. _ I
HAVE CLERK ADMINISTER OATH TO THE PANEL
l. Is any member of the panel related to the plaintiffs? They are Willie Davis, Jr.,
Nathaniel Briddell, Joseph Garnson, Larry E. Gibbs and Roy H. Walters? ‘
2. Is any member of the panel related to the defendant or personally acquainted with
any officer, director, or employee of, or ever done business with, Mountaire Farms?
3. Is any member of the panel related to, or personally acquainted with Jeffrey
Martin, plaintiffs’ attorney or ever been represented by him or another member of his law firm,
I Martin & Wilson?
4. Is any member of the panel related to, or personally acquainted with Arthur
Brewer or Eric I-Iemmendinger, defenda.nt’s attorneys or ever been represented by him or by any .
associate or member of their law firm, Shawe & Rosenthal? Is any member of the panel related
to, or personally acquainted with Matthew Boyer, defendant’s attorneys or ever been represented _
by him or by any associate or member of his law firm, Connolly, Bove, Lodge & Hutz?
- 5. Is any member of the panel related to, or personally acquainted with, any of the
following individuals who. might appear as witnesses in this case:
r l

S Case 1 :04-cv—00414-SLR Document 1 1 1 Filed 07/22/2008 Page 3 ot 3
Willie Davis, Jr., Nathaniel Briddell, Joseph Garrison, Larry E. Gibbs and Roy H.
l Walters, Phillip Owen, Douglas Lynch, David Nuse, Susan McCauley, Alan Zlotorzynski
6. Does any member of the panel have any personal knowledge of this case, or have
you read or heard it discussed, or have any opinion regarding it?
7. Has any member of the panel ever served as a juror in a Fair Labor Standards Act
or other lawsuit involving wage and hour law? ·
. 8. Does any member of the panel have any experience with, or knowledge of the
l Fair Labor Standards Act or other wage andhour laws?
9. Do you have any strong feelings about lawsuits in general?
l0. If so, would you be unable to render a fair and impartial verdict based solely upon
the evidence present in court and under the law as presented to you?
_ ll. Have you ever been party in a lawsuit?
_ 12. Have you or any member of your family ever made a claim or had a claim made
against you based upon overtime compensation?
13. Do you know of any other matter which- you believe should be called to the
Court’s attention as to having some bearing upon your qualifications or ability to sit as a juror, or
which you think may prevent you from rendering a fair and impartial verdict based solely upon
the evidence in my instructions as to the law'?

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