Page 1 - Plaintiff’s Requested Voir Dire Questions 

4822-9111-9452.1 

Elisa J. Dozono, OSB No. 063150 

elisa.dozono@millernash.com 

Vanessa L. Triplett, OSB No. 154387 

vanessa.triplett@millernash.com 

MILLER NASH GRAHAM & DUNN LLP 

3400 U.S. Bancorp Tower 

111 S.W. Fifth Avenue 

Portland, Oregon 97204 

Telephone: 503.224.5858 

Facsimile: 503.224.0155 

Attorneys for Plaintiff 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

CONSTANCE GEORGE, 

Plaintiff, 

v. 

HOUSE OF HOPE RECOVERY; 

BRIDGES TO CHANGE, INC.; 

WASHINGTON COUNTY 

DEPARTMENT OF HOUSING 

SERVICES, and PATRICIA BARCROFT, 

Defendants. 

Case No. 3:15-cv-01277-SB 

PLAINTIFF’S REQUESTED VOIR DIRE 

QUESTIONS 

Plaintiff, Constance George, requests 15 minutes for attorney-conducted voir dire 

and also requests that the Court consider the following questions for general voir dire: 

Case 3:15-cv-01277-SB Document 102 Filed 02/28/18 Page 1 of 4
 

Page 2 - Plaintiff’s Requested Voir Dire Questions 

4822-9111-9452.1 

1. Does anyone feel that it is wrong to bring a lawsuit over being treated differently from 

someone else? 

2. You are being asked to do your civic duty and act as citizen judges. Both sides are here 

because they were unable to resolve the case without you. Is there anyone here that is 

going to hold that against either side? 

3. Does anyone have experience as a landlord? 

4. Has anyone been homeless? 

5. Does anyone have family or close friends who live or have lived at a halfway house or 

other sort of recovery facility? 

6. Does anyone have family or close friends who work for religious institutions? 

7. Does anyone have family or close friends who are a current or former employee of, or a 

resident of, House of Hope? 

8. Does anyone worship, or have family or close friends who worship, at Living Hope 

Fellowship? 

9. Have you or a family member or close friend ever been a plaintiff or a defendant in a 

lawsuit? 

10. Has anyone ever been evicted from their residence or have family or close friends who 

have been evicted? 

11. Have you or a family member or close friend had experience with discrimination 

claims—either being discriminated against or being accused of discrimination? 

12. Have you or a family member ever felt that you were retaliated against for complaining 

about something that you felt that you had a legitimate right to complain about? 

Case 3:15-cv-01277-SB Document 102 Filed 02/28/18 Page 2 of 4
 

Page 3 - Plaintiff’s Requested Voir Dire Questions 

4822-9111-9452.1 

13. Does anyone have an issue with the way that civil rights laws are used or enforced? 

14. After Ms. George has proved that defendants are liable, you will be asked to assess 

damages. Damages may include what is called economic damages (tangible damages), 

noneconomic damages (intangible damages) and punitive damages. You will be asked to 

determine the amount without mathematical guidance, based on testimony that does not 

include any calculations. Does anyone feel that they would be unable to listen fairly to 

the evidence on either type of damages and decide on an amount? 

DATED: February 28, 2018. 

MILLER NASH GRAHAM & DUNN LLP 

s/ Elisa J. Dozono 

Elisa J. Dozono, OSB No. 063150 

elisa.dozono@millernash.com 

Vanessa L. Triplett, OSB No. 154387 

vanessa.triplett@millernash.com 

Telephone: 503.224.5858 

Facsimile: 503.224.0155 

Attorneys for Plaintiff 

Case 3:15-cv-01277-SB Document 102 Filed 02/28/18 Page 3 of 4
 

Page 1 - Certificate of Service 

MILLER NASH GRAHAM & DUNN LLP ATTORNEYS AT LAW 

TELEPHONE: 503.224.5858 

3400 U.S. BANCORP TOWER 

111 S.W. FIFTH AVENUE 

PORTLAND, OREGON 97204 

CERTIFICATE OF SERVICE 

I hereby certify that I served the foregoing on: 

Ms. Rebecca Cambreleng 

Cambreleng Law, LLC 

806 S.W. Broadway, Suite 1200 

Portland, Oregon 97205 

Attorney for Defendants House of 

Hope Recovery and Patricia 

Barcroft

by the following indicated method or methods on the date set forth below: 

 CM/ECF system transmission. 

 E-mail. (Courtesy copy.) 

 E-mail. As required by Local Rule 5-11, any interrogatories, requests for 

production, or requests for admission were e-mailed in Word or WordPerfect 

format, not in PDF, unless otherwise agreed to by the parties. 

 First-class mail, postage prepaid.

 Hand-delivery.

 Overnight courier, delivery prepaid.

DATED: February 28, 2018. 

s/ Elisa J. Dozono 

Elisa J. Dozono, OSB No. 063150 

elisa.dozono@millernash.com 

Of Attorneys for Plaintiff 

Case 3:15-cv-01277-SB Document 102 Filed 02/28/18 Page 4 of 4