Free Proposed Voir Dire - District Court of Delaware - Delaware

Case 1 :04-cv-00193-SLR Document 130 Filed 06/03/2008 Page 1 of 3
VOIR DIRE TO JURY PANEL
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: Anibal Melendez v. Nate
Gardels and Michael Allen. Briefly stated, this case is a civil action brought by plaintiff Anibal
Melendez against the defendants Nate Gardels and Michael Allen.
The trial is expected to last from today until tomorrow; our trial days will run
approximately 9:00 a.m. to 5:00 p.m.
Plaintiff is represented by Edward M. McNally and Jason C. J owers, attorneys with
Morris James LLP. Defendants are represented by Catherine Damavandi, an attorney with the
State of Delaware.
In the light of this brief summary, I will ask the panel certain questions, the purpose of
which is to: (l) enable the court to determine whether or not any prospective juror 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 questions "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.
HAVE CLERK ADMINISTER THE OATH TO THE PANEL
l. Is any member of the panel related to the plaintiff?
2. Is any member of the panel related to the defendants or personally acquainted
with any officer, director, or employee of, or ever done business with, the Delaware Department
of Corrections?

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3. Do you or any member of your family (i. e., spouse, children, parents, siblings or
significant others) have any relationship or significant feelings against the State of Delaware, its
departments, divisions or offices?
4. Have you or any member of your immediate family (i. e., your parents, their
brothers or sisters, your siblings, your children, your in-laws and any significant other person in
your life) been held in custody in any correctional facility?
5. Is any member of the panel related to, or personally acquainted with Mr. McNally
or Mr. J owers, plaintiffs attorneys, or ever been represented by them or by any associate or
member of their law firm, Morris James LLP?
6. Is any member of the panel related to, or personally acquainted with Ms.
Damavandi, defendants’ attomey or ever been represented by her or by any associates or
member of the Delaware Department of Justice?
7. 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:
Anibal Melendez
Brian Stewart
Curtis Evans
Nate Gardels
Michael Allen
8. Does any member of the panel have any personal knowledge of this case, or have
you read or heard it discussed, or have an opinion regarding it?
9. Has any member of the panel ever been a plaintiff or a defendant in a civil
lawsuit?
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l0. Has any member of the panel ever served as a juror in a civil rights lawsuit?
l 1. Does any member of the panel have any experience with, or knowledge of`, the
Delaware Correctional Center?
12. Does any member ofthe panel have any special disability or problem that would
make it difficult or impossible for you to serve as a member of the jury in this case?
l3. Does any member of the panel know of any other matter which you believe
should be called to the court’s attention as 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 and my instructions as to the law?
178:2265/1
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