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Case 2:15-cv-07503-MWF-JC Document 254 Filed 09/19/16 Page 1 of 5 Page ID #:9579

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Brandon Anand, Esq. (SBN: 262183)


ANAND LAW, PC
5455 Wilshire Blvd., Ste. 1812
Los Angeles, CA 90036
Telephone: 323-325-3389
Facsimile: 323.488.9659
Email: brandon@anandlaw.com
WAUKEEN Q. McCOY, ESQ. (SBN: 168228)
McCoy Law Firm, PC
555 Montgomery Street, Suite 1100
San Francisco, California 94111
Telephone (415) 675-7705
Facsimile (415) 675-2530
Attorneys for Plaintiff
JANE DOE

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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JANE DOE (A Pseudonym),

Case No. CV 15-7503-MWF(JCx)

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Plaintiff,

PLAINTIFF DOES PROPOSED


VOIR DIRE QUESTIONS

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v.

PRETRIAL CONFERENCE:
Date:
September 20, 2016
Time:
9:30 a.m.
Location: Courtroom 1600
Judge:
Hon. Michael Fitzgerald

DERRICK ROSE, an Individual;


RANDALL HAMPTON, and
Individual; RYAN ALLEN, an
Individual; and DOES 1-10 Inclusive,

Trial Date:

October 4, 2016

Defendants.

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PLAINTIFF JANE DOES PROPOSED VOIR DIRE QUESTIONS

Case 2:15-cv-07503-MWF-JC Document 254 Filed 09/19/16 Page 2 of 5 Page ID #:9580

Plaintiff Jane Doe submits the following proposed voir dire questions:

1. Do you have any significant difficulty understanding spoken English?

2. Do you have any health issues that would prevent you from serving on this

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jury?
a. Do you have any health issues that prevent you from sitting
throughout the day?
b. Do you have any health issues that would prevent you from being able
to listen to and understand the trial proceedings?
c. Do you have any visual or hearing impairment that may preclude you
from serving on this jury?
3. This trial is expected to last at least 10 days.

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a. During that time do you have any preplanned vacations?

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b. Do you have any work hardships that would prevent you from serving

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on a jury for that period of time?

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c. Are you the primary caregiver for a dependent, such as a young child

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or elderly or disabled adult? If so, would those duties prevent you

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from serving on this jury?

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d. Do you have any other unavoidable commitments during the coming


weeks that would prevent you from serving on this jury?
4. This trial involves an allegation of Rape of the Plaintiff by three men,
Derrick Rose, Randall Hampton, and Ryan Allen.
a. Do you personally know any of the persons or entities previously
mentioned?
b. Have you had any personal interaction with any of the persons
previously mentioned?
c. Has anyone talked with any of you about this case, or discussed this
case in your presence?

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PLAINTIFF JANE DOES PROPOSED VOIR DIRE QUESTIONS

Case 2:15-cv-07503-MWF-JC Document 254 Filed 09/19/16 Page 3 of 5 Page ID #:9581

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d. Other than what was mentioned above, do you have any familiarity
with the facts of this particular case?
i. Will this previous knowledge prevent you from rendering a fair

and impartial verdict based solely upon the evidence presented

and the law as given to you by the Court?

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e. Have any of you formed or expressed an opinion as to the merits of


this case?

i. Is that opinion based upon what you have read in newspapers?

ii. Do you think a celebrity should be treated the same as any other

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individual?

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iii. Do you favor famous people over others?

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iv. Would you be unable to set aside such an opinion and render a

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fair and impartial verdict based solely upon the evidence

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presented and the law as given to you by the court?

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f. Have you formulated any opinions as to what a woman should do in a


situation when she has been raped?
i. Do you think that every woman should react in the same way
when she is raped?
ii. Have you known anyone in your family that has been sexually
assaulted?

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iii. Has anyone in the room been sexually assaulted?

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iv. Do you think that it should be required for women who are

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sexually assaulted to report the assault that same day?

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v. Will you be able to render a verdict in favor of Plaintiff if she

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had been sexually assaulted but did not report the sexual assault

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to the police that same or next day?

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vi. What opinions do you have about consensual sexual


intercourse?

PLAINTIFF JANE DOES PROPOSED VOIR DIRE QUESTIONS

Case 2:15-cv-07503-MWF-JC Document 254 Filed 09/19/16 Page 4 of 5 Page ID #:9582

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vii. Do you think that a person can consent to sexual intercourse


when they are intoxicated?
viii. Do you think that a person can consent to sexual intercourse
when they are unconscious?
ix. Do you think that if someone invites you over to their home at

1:00 am that you have gained consent to have sexual

intercourse with them?

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x. What are your opinions of three men having sexual intercourse


with one woman?
5. The attorneys in this matter include: (Attorneys names)

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a. Do you personally know any of these persons?

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b. Have any of these attorneys previously represented you or someone

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who sued you before?


c. Have you ever been employed by these persons or their law firms?

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6. Do you have any personal interest in the result of this trial?

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7. Do you know any of the following persons:

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a. [Read list of witnesses from final list]

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b. What is your particular relationship to [person mentioned]?

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c. Do you believe your relationship with [said person] would prevent

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you from both (1) serving on this jury; and (2) rendering a fair verdict

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based only on the evidence and law as presented to you?

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8. The Plaintiff in this case is Mexican American? Do you have any biases or

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prejudices against Mexican Americans that would prevent you from deciding

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this case in a fair and impartial manner?

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o In your opinion, does race influence the treatment he or she receives


in Court?
o Would you feel uncomfortable awarding a large sum of money to
Plaintiff?

PLAINTIFF JANE DOES PROPOSED VOIR DIRE QUESTIONS

Case 2:15-cv-07503-MWF-JC Document 254 Filed 09/19/16 Page 5 of 5 Page ID #:9583

Dated: September 19, 2016

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/s/ Waukeen McCoy


BRANDON ANAND, ESQ.
WAUKEEN MCCOY, ESQ.
Attorneys for Plaintiff
JANE DOE

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PLAINTIFF JANE DOES PROPOSED VOIR DIRE QUESTIONS