Defendant's proposed voir dire: age, race (fed.)

DEFENDANT'S PROPOSED VOIR DIRE QUESTIONS

1. Do you know the Plaintiff or her attorneys?

2. Do you know _________ or his attorneys?

3. Have you or any members of your family ever been employed by __________ Corporation or __________?

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

   a) 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?

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

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

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

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

   a) 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?

9. Have you ever done business with _________ or ___________ Corporation?

10. Do you or any member of your family have any reason to complain about _________ or __________ Corporation?

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

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

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

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

15. Do you feel an employer in reducing costs and expenses, must attempt to relocate employees rather than eliminating jobs?

16. In this case, Plaintiff says that at age 49 she was discriminated against because of her age, race and national origin. Defendants deny these claims. Do you feel that because of the nature of Plaintiff's claims or for any...