IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

DELOISE PRICE, | 

 | 

 PLAINTIFF | 

 | 

VS. | CASE NO. 2:06-CV-721 

 | 

WAL-MART STORES, INC., | 

et al., | 

 | 

 DEFENDANTS | 

DEFENDANTS REQUESTED VOIR DIRE QUESTIONS

 Come now defendants and submit the following list of requested voir dire 

questions to be used at the trial of this case in addition to the questions contained in 

the Federal Juror Questionnaire: 

ADDITIONAL VOIR DIRE

1. Do any of you know Mrs. Price’s first husband Willie Lee Beverly? 

2. Did any of you know Deloise Beverly of Camden? 

3. Have any of you ever attended or are you a member of the Hope 

Ministry International Holiness church near the Red Lion Apartments in 

Montgomery? 

4. Have you ever been represented by Jock M. Smith or Brian P. 

Strength or anyone at the law firm of Cochran, Cherry, Givens & Smith? 

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5. Do you know, even in the slightest, any of the above lawyers or 

anyone who works for their law firm of Cochran, Cherry, Givens & Smith in 

Dothan or Tuskegee? If so, please state how you know them. 

6. Do you know any of the following witnesses the plaintiff may call in 

this case? If so, please state who you know and how you know them: 

a. Willie J. Price of 5850 Carriage Brook Road. 

b. Michelle Jackson of 2910 Peabody Road. 

c. Ella Frazer of 5751 Red Barn Road. 

d. Willie L. Beverly, Jr. of 5850 Carriage Brook Road. 

e. Martha Mack of 9306 Country Road 26 in Hope Hull. 

f. Dr. Glenn Chesnutt, a chiropractor with an office at 

5931 Carmichael Road. 

g. Dr. Rosanne Cook of Pine Apple, AL. 

7. Do any of you live near 5850 Carriage Brook Road in 

Montgomery? 

8. Have any of you used what is known as an elliptical exercise 

machine which involves moving foot pedals and handle bars back and forth? 

9. Are any of you presently covered under the Medicaid program like 

Mrs. Price? 

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10. Have any of you lived in Wilcox County where Mrs. Price is 

originally from? If so, please state: 

a. How long ago did you last live there? 

b. Did you ever live in Camden? 

c. Did any of you attend Camden Academy where Mrs. Price went to 

school? 

d. Are you familiar with Bill’s Dollar Store in Camden? 

11. Do you or any member of your family currently receive disability 

benefits from the government? If so, please state the nature of the disability or 

what causes the disability. 

12. Do any of you receive a newsletter published by any lawyers? If 

so, what is the name of the lawyer or law firm that sends you the newsletter? 

13. Those of you who have served on civil juries in the past please 

stand and state: 

a. What the case was about,and 

b. What the result was. 

14. Those of you who have testified in a civil case in court before, 

please stand and state 

a. What the case was about, 

b. What you testified about,and 

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c. Who called you as a witness. 

15. Do any of you work in a job that requires you to be familiar with 

the Medicaid or Medicare programs and the benefits provided by those programs? 

16. Have any of you purchased any home exercise equipment such as 

exercise bikes, treadmills, elliptical machines or the like? If so, please identify: 

a. What equipment you have purchased; 

b. Where you purchased it from. 

c. Whether any assembly was required by you before using it. 

17. Do any of you hold any ill will or negative feelings toward WalMart or Sam’s Club in general? If so, can you put aside those feeling and be fair to 

Wal-Mart in this case? 

18. Have you ever worked for a Wal-Mart or Sam’s Club? If so, state: 

a. Your position with the store, 

b. If no longer employed your last date of employment, 

c. Whether you had a positive or negative feeling about Wal-Mart or 

Sam’s Club after working there. 

19. Have any of you ever purchased a product from a Sam’s Club or 

Wal-Mart that was assembled by the employees of the store? If so, please ask them 

to approach the bench before asking the following questions: 

a. If so, what was the product you purchased? 

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b. What store did you purchase it from? 

c. Approximately how long ago? 

d. Do you remember whether you were charged anything for the 

assembly? 

 /s/ Dennis R. Bailey

 Dennis R. Bailey 

 Attorney for Defendants 

Of counsel: 

RUSHTON, STAKELY, JOHNSTON & GARRETT, P.A. 

184 Commerce Street 

Post Office Box 270 

Montgomery, Alabama 36101-0270 

(334) 206-3234 (phone) 

(334) 481-0031 (fax) 

drb@rsjg.com (e-mail) 

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CERTIFICATE OF SERVICE

 I hereby certify that I have filed the foregoing pleading through the ECMF 

system on this the 9th day of November, 2007, which will forward same to: 

 Jock M. Smith 

 Brian P. Strength 

 Valerie Rucker Russell 

 Cochran, Cherry, Givens, Smith, Lane & Taylor 

 Post Office Box 830419 

 Tuskegee, Alabama 36083 

 /s/ Dennis R. Bailey

 Of counsel 

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