Free Proposed Voir Dire - District Court of California - California

Case 3:07-cv-02748-MHP

Document 162

Filed 04/14/2008

Page 1 of 5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

WILLIAM R. HILL, #114954 [email protected] ANDREW S. MACKAY, #197074 [email protected] SARA J. ROMANO, #227467 [email protected] DONAHUE GALLAGHER WOODS LLP Attorneys at Law 300 Lakeside Drive, Suite 1900 Oakland, California 94612-3570 P.O. Box 12979 Oakland, California 94604-2979 Telephone: (510) 451-0544 Facsimile: (510) 832-1486 Attorneys for Plaintiff MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS, Plaintiff, v. ANDREW VERITY and CHRISTINA CHANG, Defendants. ANDREW VERITY and CHRISTINA CHANG, Counterclaimants, v. MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS, and DOES 110, Counterdefendants. CASE NO. C 07-02748 MHP [PROPOSED] JOINT VOIR DIRE QUESTIONS Date: Time: Dept.: Judge: May 6, 2008 8:30 a.m. Courtroom 15, 18th Floor Hon. Marilyn H. Patel

[PROPOSED] JOINT VOIR DIRE QUESTIONS

CASE NO. C 07-02748 MHP

Case 3:07-cv-02748-MHP

Document 162

Filed 04/14/2008

Page 2 of 5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Plaintiff Mark Lillge d/b/a/ Creative Marketing Concepts and Defendants Andrew Verity and Christina Chang hereby propose the following voir dire questions for use at trial: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. organizations? 18. 19. 20. 21. Describe any offices you have held in these organizations. Do you know anyone on this jury panel? On how many cases have you served on a jury? Where did you serve on a jury? -1CASE NO. C 07-02748 MHP

Please state your name, date, place of birth and marital status. Where do you live? Where else have you lived in the past 10 years and dates? What is the highest level of education you completed? If you plan to attend or are currently attending school, please describe. Please describe any courses or training in law or a related subject. Please describe the educational background of your spouse, including any degrees What is your present employment status? What is your current or most recent occupation? Name of your current or most recent employer or, if a student, your school. What are your specific duties and responsibilities on the job? Please describe all other full time employment. Please describe all full time employment of your spouse/former spouse. Please describe all full time employment of any other adult who lives in your What are/were the occupations of your parents? (If your parents are retired, what If you have children, please list their sex, age, education and occupation (including Are you affiliated with any social, civic, professional, trade, or other

or certificates earned.

home (and for how long the adult has held the job). did they do before retirement?). any children who do not currently live with you).

[PROPOSED] JOINT VOIR DIRE QUESTIONS

Case 3:07-cv-02748-MHP

Document 162

Filed 04/14/2008

Page 3 of 5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

22. 23. 24. 25. 26. 27. 28. explain. 29. 30. explain. 31. 32.

What kinds of cases did you hear while serving on a jury? In how many of those cases did the jury reach a verdict? In how many of those cases did you serve as the jury foreperson? If you have ever been to court for any other reason (besides as a juror or for If you have relatives or close personal friends who are judges or attorneys or court Describe any problems (vision, hearing, or other medical problems) that may If you or anyone close to you has ever made any type of claim for damages, If a claim for money damages has ever been made against you or anyone close to If you or anyone close to you has ever sued or been sued in any type of lawsuit, If you have any ethical, religious, political, or other beliefs that may prevent you Have you, your parents, your spouse, any adult you have lived with, your

divorce), please explain. personnel, what are their names and relationship to you? affect your jury service.

you, explain the circumstances.

from serving as juror, please explain. children, your siblings, anyone close to you, or an acquaintance, as applicable, ever been employed by Mark Lillge d/b/a/ Creative Marketing Concepts, Andrew Verity, Christina Chang, Branding Boulevard, or Verity Marketing? If so, please list the person's job title, years of employment, and specific duties or responsibilities on the job. 33. Have you, your parents, your spouse, any adult you have lived with, your children, your siblings, anyone close to you, or an acquaintance, as applicable, ever been fired from employment? Who was your employer? What was the reason for the firing? 34. 35. Which newspapers do you read and how often? Do you use the Internet and, if so, how often? -2[PROPOSED] JOINT VOIR DIRE QUESTIONS
CASE NO. C 07-02748 MHP

Case 3:07-cv-02748-MHP

Document 162

Filed 04/14/2008

Page 4 of 5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 what?

36.

Have you, your parents, your spouse, any adult you have lived with, your children,

your siblings, anyone close to you, or an acquaintance, as applicable, ever been an owner or part owner of a business? If so, please state the person's name, relationship to you, the name of the business, and the nature of the business interest. 37. Do you have anything against or have you had any disputes or bad experiences with Mark Lillge d/b/a/ Creative Marketing Concepts, Andrew Verity, Christina Chang, Branding Boulevard, or Verity Marketing? If so, please describe. 38. Have you heard any negative comments about Mark Lillge d/b/a/ Creative Marketing Concepts, Andrew Verity, Christina Chang, Branding Boulevard, or Verity Marketing? If so, what? 39. contracts? 40. 41. 42. 43. 44. 45. business? 46. 47. 48. 49. 50. Have you ever performed due diligence in the purchase or sale of a business? Have you ever claimed any ownership interests in any intellectual property rights, Have you ever owned or run your own business? Have any of your family members ever owned or run their own business? Have you ever had a business partner? If so, please describe the experience, -3Have you ever had a dispute with or made a complaint to an employer? If so, Have you ever sued an employer? Have you ever been sued by an employer? If Does your job involve supervising other people? Are you involved in the hiring or firing of other people? Are you involved in evaluating the job performance of other employees? Have you ever bought or sold a business? What was the name and type of Have you worked with contracts in any way, such as writing contracts or enforcing

so, please explain.

such as copyrights, trademarks, patents, or trade secrets? If so, please describe.

including whether you had any disputes with your partner and how they were resolved.
[PROPOSED] JOINT VOIR DIRE QUESTIONS
CASE NO. C 07-02748 MHP

Case 3:07-cv-02748-MHP

Document 162

Filed 04/14/2008

Page 5 of 5

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

51.

Do you have any strong feelings one way or another about businesses or former

business partners resolving a dispute in a court of law versus using other methods to resolve it? If so, please describe your feelings on this topic. 52. 53. experience. 54. Do you have strong perceptions one way or another of people who work in the sales and marketing industry? Have you had a negative experience with someone in the sales and marketing industry? 55. 56. Have you had any experiences with corporate agreements such as confidentiality Do you have any strong opinions regarding foreign citizens working in the United or non-disclosure agreements or a non-compete clause? If so, please describe your experience. States? If so, please describe your opinions. Dated: April 14, 2008 Respectfully submitted, DONAHUE GALLAGHER WOODS LLP By: /s/ William R. Hill William R. Hill Attorneys for Plaintiff MARK LILLGE d/b/a CREATIVE MARKETING CONCEPTS Have you ever left a company to go and work for a competitor? What happened? Have you ever worked in sales or marketing? If so, please describe the

-4[PROPOSED] JOINT VOIR DIRE QUESTIONS
CASE NO. C 07-02748 MHP