IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

MELISSA MCFADDEN,

Case No. 2:18-cv-544

Plaintiff,

Judge Edmund A. Sargus, Jr.

v.

Magistrate Judge Jolson

CITY OF COLUMBUS, 

DEFENDANT’S PROPOSED

Defendant. VOIR DIRE QUESTIONS

1. Knowing the subject of this case, is there anyone who is uncomfortable sitting on this jury? 

2. Knowing the subject of this case, is there anyone who really wants to sit on this jury? 

3. Have you, or has anyone close to you, ever been discriminated against or retaliated against, 

either in the workplace or anywhere else?

4. Have you, or has anyone close to you, ever been accused of discrimination or retaliation, 

either in the workplace or anywhere else?

5. Have you ever been involved in an investigation into claims of discrimination or 

retaliation?

6. Have you, or has anyone close to you, ever been involved in a discrimination or retaliation 

lawsuit?

7. Have you, or has anyone close to you, ever sued an employer or former employer? 

8. Has your employer ever been sued by someone who was alleging discrimination or 

retaliation?

9. If you own or ever have owned a business or been self-employed, were you ever sued by 

someone who was alleging discrimination or retaliation?

10. Have you, or has anyone close to you, ever been involved in an Equal Employment 

Opportunity Commission or the Civil Rights Commission case?

11. Have you, or has anyone close to you, ever filed a worker’s compensation claim?

12. How much respect do you have for the police in your community?

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13. Have you had any interactions with the Columbus Division of Police? 

14. How much respect do you have for the Columbus Division of Police?

15. Have you, or has anyone close to you, ever been mistreated by the police?

16. Do you believe that Black people are generally treated less fairly than White people when 

dealing with the police? 

17. Have you taken any steps in response to policing issues (such as protesting, or posting on 

social media, or putting up yard signs)? 

18. Have you used any derogatory terms when referring to the police (such as Pigs, ACAB—

All Cops are Bastards, Fuck the Police, Fuck 12). 

19. Do you support defunding the police?

20. Do you support abolishing the police?

21. Are you a participant in any social justice or civil rights movements or organizations (such 

as the People’s Justice Project or Showing Up For Racial Justice)? 

Respectfully Submitted,

/s/ Paul M. Bernhart

Westley M. Phillips (0077728)

Susan E. Williams (0073375)

Paul M. Bernhart (0079543)

Assistant City Attorneys

CITY OF COLUMBUS, DEPARTMENT OF LAW

ZACH KLEIN, CITY ATTORNEY

77 North Front Street, Columbus, Ohio 43215

(614) 645-7385 / (614) 645-6949 (fax)

wmphillips@columbus.gov

sewilliams@columbus.gov

pmbernhart@columbus.gov

Attorneys for Defendant

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CERTIFICATE OF SERVICE

I hereby certify that on May 25, 2022, I electronically filed the foregoing with the Clerk of 

the Court by using this Court’s CM/ECF system, which will send a notice of this electronic filing 

to all counsel of record in this matter.

/s/ Paul M. Bernhart

Paul M. Bernhart (0079543)

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