Toffoloni v. LFP Publishing Group, LLC

Filing 190

Proposed Voir Dire by Maureen Toffoloni. (Decker, Richard)

ATTACHMENT B-3
Joint questions to be presented to Jurors in writing
The Parties request that the following questions be posed to the potential jurors in
writing. The Parties also request the opportunity to ask follow-up questions of
individual jurors privately.
1.

Have you or anyone close to you ever had training or been employed in the
pornography industry?

2.

Have you or anyone close to you ever been employed by Larry Flynt
Publications, or “LFP Publishing Group, LLC”?

3.

Have you ever read or looked through a Hustler Magazine?

4.

Have you ever purchased an issue of Hustler Magazine?

5.

Do you subscribe to Hustler Magazine or purchase Hustler Magazine on a
regular basis?

6.

Do you subscribe to Playboy Magazine or purchase Playboy Magazine on a
regular basis?

7.

Do you subscribe to Penthouse Magazine or read Penthouse Magazine?

8.

Do you now or have you ever subscribed to any adult or pornographic
magazine or purchased any pornographic magazine on a regular basis? Do you
look at pornography on the internet?

9.

Have you ever watched an R-rated movie containing sexually explicit
material?
a.

If “YES”, how often have you watched such movies?

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10.

Have you ever watched a so-called X-rated or pornographic film?
a.

11.

Have you ever purchased or rented a X-rated video or pornographic film?
a.

13.

If “YES”, how many such films have you seen?

If “YES”, how many such films or videos have you purchased in the
last 10 years?

Do you now or have you ever had a subscription to a cable, satellite or other
for-pay television channel offering adult/pornographic programming?
a.

If “YES”, to which channels do you subscribe and for how long have
you had each subscription?

3197-007/Pleading/37156.DOC

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