EXHIBIT I 

Case 3:17-cv-00600-LB Document 120-9 Filed 09/06/19 Page 1 of 4
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 Case No. 3:17-cv-00600-LB

PLAINTIFF’S PROPOSED VOIR DIRE QUESTIONS 

MIRIAM KIM (State Bar No. 238230) 

miriam.kim@mto.com 

EMILY C. CURRAN-HUBERTY (State Bar No. 293065) 

emily.curran-huberty@mto.com 

SKYLAR D. BROOKS (State Bar No. 310707) 

skylar.brooks@mto.com 

MUNGER, TOLLES & OLSON LLP 

560 Mission Street 

Twenty-Seventh Floor 

San Francisco, California 94105-2907 

Telephone: (415) 512-4000 

Facsimile: (415) 512-4077 

Attorneys for Plaintiff 

RENEE LEPAGE 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION 

RENEE LEPAGE, an individual, 

Plaintiff, 

vs. 

COUNTY OF NAPA; COUNTY OF NAPA 

SHERIFF’S DEPARTMENT; AND DEPUTY 

TIMOTHY REID, 

Defendants. 

 Case No. 3:17-cv-00600-LB 

PLAINTIFF’S PROPOSED VOIR DIRE 

QUESTIONS 

 

Case 3:17-cv-00600-LB Document 120-9 Filed 09/06/19 Page 2 of 4
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 -2- Case No. 3:17-cv-00600-LB

PLAINTIFF’S PROPOSED VOIR DIRE QUESTIONS 

 Plaintiff Renee LePage proposes the attached voir dire questions for the trial of this matter. 

Ms. LePage separately submitted a proposed jury questionnaire that contains some 

additional questions. Defendants object to the use of a jury questionnaire. To the extent the Court 

decides not to use a jury questionnaire or omits any of the questions in Ms. LePage’s proposed 

jury questionnaire, Ms. LePage respectfully requests that the questions be asked during voir dire. 

DATED: September 6, 2019 MUNGER, TOLLES & OLSON LLP 

By: /s/ Miriam Kim 

 MIRIAM KIM 

Attorneys for Plaintiff 

RENEE LEPAGE 

Case 3:17-cv-00600-LB Document 120-9 Filed 09/06/19 Page 3 of 4
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 -3- Case No. 3:17-cv-00600-LB

PLAINTIFF’S PROPOSED VOIR DIRE QUESTIONS 

PROPOSED VOIR DIRE QUESTIONS 

1. Do you know anyone who has ever been employed by the San Mateo County Sheriff’s 

Office? If so, please explain. 

2. Would you tend to believe the testimony of a law enforcement officer simply because he/she 

is a law enforcement officer? 

3. Would you tend to believe the testimony of a law enforcement officer as more accurate or 

reliable than the testimony of an average person? 

4. Have you, a relative or close friend ever been accused of excessive force while working in 

law enforcement? If so, please explain. 

5. Have you, a relative or close friend ever been sued based on conduct that took place while 

working in law enforcement? If so, please explain. 

6. Have you, a relative or close friend ever been sued in any type of lawsuit? If so, please 

explain. 

7. Have you, a relative or close friend ever been accused of abuse or excessive force? If so, 

please explain. 

8. Do you have any personal objection to lawsuits against law enforcement officers? If so, 

please explain. 

9. Do you have any personal objection to lawsuits that seek monetary compensation for pain 

and emotional suffering? If so, please explain. 

10. Do you have any personal objection to lawsuits that seek monetary compensation for 

punitive damages? If so, please explain. 

DATED: September 6, 2019 MUNGER, TOLLES & OLSON LLP 

By: /s/ Miriam Kim 

 MIRIAM KIM 

Attorneys for Plaintiff 

RENEE LEPAGE 

Case 3:17-cv-00600-LB Document 120-9 Filed 09/06/19 Page 4 of 4