Free Proposed Voir Dire - District Court of Arizona - Arizona

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John E. Karow, SBN 014200 LAW OFFICE OF JOHN E. KAROW 11350 North 104th Place Scottsdale, Arizona 85259 (480) 391-2236 (480) 391-0132 Attorneys for Defendant

IN THE UNITED STATES DISTRICT COURT 6 FOR THE DISTRICT OF ARIZONA 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Defendant. _____________________________________ LINDA HINTON, an individual, Plaintiff, vs. PROGUARD SECURITY, an Arizona corporation, ) ) ) ) ) ) ) ) ) ) ) No. CIV 03-1985-PHX-SRB

JOINT PROPOSED VOIRE DIRE (Assigned to the Hon. Susan R. Bolton)

Defendant ProGuard Security submits the following proposed Voir Dire questions pursuant to the Court's Rule 16 Scheduling Order dated May 17, 2004: 1. Each of you should now state your name, where you live, your marital

status (whether married, single, widowed or divorced), the number and ages of your children, if any, your education and your employment history (including the names of your current and former employers). If you are married, you should also briefly describe your spouse's education and employment history. Please begin with juror no. 1. 2. this case? 3. Is there any member of the jury panel who knows of, or who has had any Is there any member of the jury panel who has personal knowledge of

business dealings with ProGuard Security? 4. Is there any member of the jury panel who was or who knows someone

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who was employed by ProGuard Security? 5. Is there any member of the jury panel who knows of or who has had any

business dealings with Linda Hinton? 6. Is there any member of the jury panel who was or who knows of

someone who was employed by Linda Hinton? 7. Is there any member of the jury panel who knows the lawyers in this

case, John Karow and Linda Hinton. 8. Is there any member of the jury panel who knows any of the following

witnesses who might be called in this case? Ryan Oberholtzer, Gerald Heller, Danielle Smith, Linda Hinton. 9. Is there anyone on the jury panel who has a fixed opinion about or a bias

­ either for or against ­ any of the parties in this case? If so, please explain what the specific opinion or bias is. 10. Is there anyone on the jury panel who has previously served as a juror?

If so, describe your previous experience (type of case, whether it went to verdict, whether you were excused, etc.)? 11. Is there anyone on the jury panel who has been, or has a family member

or close friend who has been, a party to a lawsuit? If so, please describe that case. Is there anyone on the jury panel who believes just because someone is a defendant in a lawsuit, that the defendant must have done something wrong? If so, why do you feel that way? 12. Have you formed any impression of our justice system that you feel

might influence your decision if you were selected to serve as a juror in this case? 13. Is there anyone on the jury panel who has worked in the security guard

industry? If so, please state the company for which you worked, your job titles, duties and dates of employment. 2 Case 2:03-cv-01985-SRB Document 66 Filed 09/26/2005 Page 2 of 4

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14.

Is there anyone on the jury panel who has been employed by any

governmental authority responsible for the regulation of members of the security guard industry? 15. Is there anyone on the jury panel who has ever owned your own

business? If so, please state the type of business in which you were engaged, the length of time in business, and number of employees in the business. 16. Is there anyone on the jury panel who has had executive or senior

management responsibility over a business or supervised or managed employees? 17. Is there anyone on the jury panel who has worked for or is familiar with

what a private security guard organization does? If so, describe your understanding of the services provided. 18. Is there anyone on the jury panel who is familiar with the concept of

workers' compensation insurance? If so, please describe your understanding of workers' compensation insurance. 19. Is there anyone on the jury panel who has ever been responsible for or

assisted with the procurement of workers' compensation insurance coverage for your company's employees? If so, please describe your experience. 20. Is there anyone on the jury panel who has filed a workers' compensation

21.

Is there anyone on the jury panel who has received and/or responded to

a workers' compensation claim by one of your company's employees? In what capacity did you respond? 22. Is there anyone on the jury panel who has had a workers compensation

claim denied? If so, why was your claim denied? Did you bring a lawsuit against any other party as a result of the denial of your claim? If so, please describe the details of your case. 3 Case 2:03-cv-01985-SRB Document 66 Filed 09/26/2005 Page 3 of 4

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