Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1 :04-cv-00320-SLR Document 73 Filed O2/O1/2008 Page 1 of 4 .
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MELVERT WASHINGTON, JR., )
)
Plaintifi )
)
v. ) ’ Civil Action No. 04-—320 (SLR)
A )
AUTOZONERS, INC., )
)
Defendant, )
PLAINTIFF’S PROPOSED VOIR DIRE
PHILLWS, GOLDMAN & SPENCE, PA
Joseph J. Farnan, III (Bar No. 3945)
1200 N. Broom St.
Wilmington, DE 19806
TEL: (302) 655—4200
[email protected]
2 and
Thomas J. Reed (admitted Pro Hoc Vice)
Widener University School of Law
Delaware Volunteer Legal Services, Inc.
Veterans Assistance Program
. 4601 Concord Pike
P.O. Box 7474
1 Wilmington, DE i9803~7474
Date: February 1, 2008

Case 1:04-cv-00320-SLR Document 73 Filed O2/O1/2008 Page 2 of 4
VOIR DIRE QUESTIONS;
l Have any of you ever worked in auto parts sales or as an auto mechanic? If °°yes" which
company did you work for? How long did you work there?
2 If anyone has had a good or bad experience working in an auto parts sales or as an auto
mechanic have any influence on your ability to weigh the evidence and follow the Judge’s
instructions on the law in this case?
3 Have any of your relatives or friends ever worked in auto parts sales or in a garage? if
"yes" which company did they work for? I-low long did they work there?
4 If you have worked in auto parts or as an auto mechanic, an auto supply story? if "yes"
which stores? How were they treated?
5 lf anyone has a relative or friend who had a good or bad experience working in an auto
supply store or department, will your knowledge of their experience with auto parts stores
have any influence on your ability to weigh the evidence and foilow the Iudge’s
instructions on the law in this case?
6 Have any of you ever lived in a racially segregated community or had any experience with
segregation?
7 if "yes" explain how you felt about segregation?
8 If anyone has, will your experiences with segregation have any infiuence on your ability
to weigh the evidence and follow the Qludge’s instructions on the law in this case?
9. Do any of you work on cars or trucks.? If "yes" please explain.
if you have worked on cars or trucks, have you bought parts or accessories from an auto
supply story? li “yes" which stores? How were you treated by the sales people?
10 If anyone has, will your experience with auto parts stores have any influence on your
ability to weigh the evidence and follow the QFudge’s instructions on the law in this case?
tl Have any of you bought auto parts, lubricants, or accessories from an auto parts store or
the auto parts department of a department store? If "yes” which store or stores?
_ _ I2 If anyone has, will your experience with auto parts stores have any influence on your
ability to weigh the evidence and follow the }udge’s instructions on the law in this case?
‘Plaintiff respectfully requests the following Voir Dire questions in addition to the
Court’s standard Voir Dire.

Case 1:04-cv-00320-SLR Document 73 Filed O2/O1/2008 Page 3 ot 4
E3 How many of you have seen TV commercials, heard radio cotnrnerciais , read newspaper
advertisements, etc. about Autozone?
14 It anyone has, will your familiarity with Aatozone’s advertising and promotional
literature have any influence on your ability to weigh the evidence and follow the J udge’s
instructions on the law in this case?
15 The Plaintiff had a job with the Delaware State University Maintenance Department
during relevant periods of time in this case: have any of you ever worked at, or attended
classes, or otherwise have any contact with Delaware State University? if "yes" have you
had any contact with Delaware State University’s Maintenance Department? Please
explain
16 lf anyone has, will your familiarity with Delaware State University have any influence on
your ability to weigh the evidence and foitow the Iudge’s instructions on the law in this
case?

Case 1:04-cv-00320-SLR Document 73 Filed O2/O1/2008 Page 4 of 4
» Respectfully submitted,
PHILLIPS, GOLDMAN & SPENCE, PA.
. y
J seph . Fa a , lll (#3945)
200 N. Broom St.
Wilmington, DE 19806
· TEL: (302) 655-4200
i j f@_pgs1aw.corn
and
Thomas J. Reed (admitted Pro Hoc Vice)
, Widener University School of Law
Delaware Volunteer Legal Services, Inc.
Veterans Assistance Program
4601 Concord Pike
P.O. Box 7474
Wilmington, DE 19803-7474
Date: February l, 2008

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