Toffoloni v. LFP Publishing Group, LLC

Filing 225

Proposed Voir Dire by LFP Publishing Group, LLC. (Bauer, S.)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
MAUREEN TOFFOLONI,
as Administrator and Personal
Representative of the ESTATE
OF NANCY E. BENOIT,

)
)
)
)
)
Plaintiff,
)
)
vs.
)
)
LFP PUBLISHING GROUP, LLC, )
d/b/a Hustler Magazine.
)
)
Defendant.
)

CASE NO. 1:08-cv-00421-TWT

REQUEST FOR WRITTEN VOIR DIRE
Per the Court’s direction, Defendant LFP Publishing Group, LLC hereby
respectfully submits this request that the attached proposed voir dire questions
(which questions were previously proposed to the Court in the Pretrial Order [D.I.
176 at Attachment B-2], as referenced) be added to the written voir dire
questionnaire prepared by the Court for submission to the potential jurors in this
matter.
[Signature on following page]

Respectfully submitted this 10th day of June 2011.

/s/ S. Derek Bauer
James C. Rawls
Georgia Bar No. 596050
Barry J. Armstrong
Georgia Bar No. 022055
S. Derek Bauer
Georgia Bar No. 042537
Darrell J. Solomon
Georgia Bar No. 305922
McKENNA LONG & ALDRIDGE LLP
303 Peachtree Street, NE, Suite 5300
Atlanta, Georgia 30308
[phone]
[phone] (facsimile)

Attorneys for LFP Publishing Group,
LLC

CERTIFICATE OF SERVICE
This is to certify that I have this day filed the within and foregoing
REQUEST FOR WRITTEN VOIR DIRE via the CM/ECF system which will
automatically send notification to Plaintiff’s attorneys of record, who are
participants in the CM/ECF system.
This 10th day of June 2011.
/s/ S. Derek Bauer
S. Derek Bauer

ATTACHMENT B-2
Defendant’s voir dire questions

3.

Are any of you, or have any of you ever been, a member of an organization
that advocates for the elimination of obscenity or for anti-pornography laws?

4.

Do any of you have any strong or religious objections to pornography or to
those individuals and companies that produce pornography?

5.

Do any of you believe that pornography should be abolished?

6.

Do you believe that photographs of women or men posing nude are
considered pornography?

7.

Have any of you or anyone you know ever been negatively affected by
pornography or the Adult Entertainment Industry?

8.

Do any of you believe that publishers of pornography have no morals?

14.

Do any of you object to the right of a person to subscribe to an adult
magazine?

15.

Do any of you object to the right of a person to read an adult magazine?

ATLANTA:5310068.1