Toffoloni v. LFP Publishing Group, LLC

Filing 193

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

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
MAUREEN TOFFOLONI,
as Administrarix and Personal
Representative of the
ESTATE OF NANCY E. BENOIT,
Plaintiff,
v.
LFP PUBLISHING GROUP, LLC,
d/b/a Hustler Magazine,
MARK SAMANSKY, an Individual,
and other distributors and sellers of,
Hustler Magazine, as
Defendants X, Y, and Z,
Defendants.

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CIVIL ACTION
FILE NO. 1:08-CV-0421-TWT

PROPOSED WRITTEN VOIR DIRE QUESTIONS
COME NOW, Plaintiff, Maureen Toffoloni, as Administratrix and
Personal Representative of the Estate of Nancy Benoit, and Defendant, LFP
Publishing Group, LLC, d/b/a Hustler Magazine, through counsel and submit the
following proposed written voir dire questions to be included with the Consolidated
Pretrial Order filed with this Court on March 28, 2011.

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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?

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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.

10.

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

11.

If "YES", how often have you watched such movies?

If "YES", how many such films have you seen?

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

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

12.

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?

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Respectfully submitted April 20, 2011.

/s/ Richard P. Decker
RICHARD P. DECKER
State Bar of Georgia #215600
For HALLMAN & WINGATE, LLC
Attorneys for Plaintiff
166 Anderson Street, S.E.
Suite 210
Marietta, Georgia 30060
[phone]
/s/ S. Derek Bauer
S. DEREK BAUER
State Bar of Georgia #042537
DARRELL J. SOLOMON
State Bar of Georgia #305922
For MCKENNA, LONG & ALDRIDGE
Attorneys for Defendant
303 Peachtree Street, N.E.
Suite 5300
Atlanta, Georgia 30308
[phone]

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