Defendant's proposed voir dire questions for judge in age, race & rif cases (fed & state)

DEFENDANT’S PROPOSED VOIR DIRE QUESTIONS

1. Does anyone know the Plaintiff?

2. Does anyone know the Plaintiff’s attorneys?

3. Does anyone know anyone working in the Plaintiff’s attorney’s law firm?

   OPTION:

4. Has anyone seen/heard Plaintiff’s attorneys billboard/TV/newspaper advertisements?

5. Have you or any members of your family ever been employed by Defendant?

6. Do you believe that you or any member of your family or any friend or acquaintance have ever been discriminated against by an employer because of age, sex, race, disability, religion or national origin?

   if so, do you feel that you would have a tendency to favor the Plaintiff in this case?

   b) if so, do you feel that you would in any way have difficulty rendering a fair and impartial verdict in this case?

7. Have you ever been a plaintiff in a lawsuit other than a divorce or family law matter?

8. Have you, a friend or any members of your family ever filed a discrimination claim, charge or lawsuit against anyone?

9. Has any company for which you have worked ever been sued for a claim of age or race discrimination?

   if so, how did you feel about that lawsuit?

10. Have you ever witnessed discrimination in the workplace?

11. Have you or any member of your family ever been fired from an employment position?

    1. if so, did you form an opinion as to whether the employer’s action was for any reason unfair?

    b) if so, do you feel that you would have a tendency to favor the Plaintiff in this case?

    c) if so, do you feel that this tendency to favor Plaintiff would in any way affect your ability to render a fair and impartial verdict in this case?

12. Have you ever done business with Defendant?

13. Do you or any member of your family have any reason to complain about Defendant?

14. Do you believe that there is anything inappropriate about a company consolidating its operations when it is losing money?

15. Do you believe there is anything inappropriate about a company that is losing money streamlining operations, even if that means elimination of offices and jobs in those offices?

16. Do you feel that an employer may fire someone for the purpose of reducing costs and streamlining operations without incurring liability?

17. Do you feel that when an employer is reducing costs and expenses, it must attempt to transfer or relocate employees before discharging them?

18. In this case, Plaintiff says that s/he was discriminated against because of...