VOIRDIRE
Good morning, ladies and gentlemen. I am Judge Williams. We are going to
select a jury in a civil case called .
I am going to ask you a series of questions to help the Court and the
attorneys in the jury selection process. Before I ask any questions, I am going to
ask the Deputy Clerk to swear the jury panel to answer any questions truthfully.
(To Deputy,Please swear the panel).
If any of you answer "yes" to any ofthe questions that I ask, please raise
your hand, and, when recognized by me,please stand, state your name and your
jury number. At the end ofthe questions, the Deputy Clerk will ask some of you to
take seats in the jury box, and, after that, the lawyers and I may ask those of you
who answered "yes" to one or more questions to come up to the bench to discuss
your answers with the lawyers and me.
The presentation of evidence in this case is expected to take days, and
arguments and jury deliberations would likely extend your service beyond that.
The schedule that I expect to keep over the days of evidence presentation will
include a morning break offifteen minutes, a limch break of an hour, and an
afternoon break offifteen minutes. We will start at 9:30 a.m. and finish no later
than 5:30 p.m. each day.
1. Does the schedule that I have just mentioned present a special problem for
any of you?
2.(Description ofthe case). This is a breach of contract lawsuit relating to
the sale of a number of companies in 2008. The Plaintiff is Safeguard Scientifics,
Inc., of Wayne,Pennsylvania. I will call it Safeguard or Plaintiff. Safeguard was
the seller ofthe companies. It has sued the Defendant, who is Saints Capital
Dakota, L.P ., of San Francisco, California I will call it Saints or Defendant.
Safeguard says it has lived up to the sales contract and that Saints owes it millions
of dollars. Saints says that Safeguard breached the contract and that Saints does
not owe Safeguard anything and that Safeguard owes it millions of dollars. The
jury in this case will be asked to decide whether there has been a breach of contract
and damages, if any. For those of you who end up being on the jury,I will give
more detailed instructions on the law later in the case.
Have any of you heard or read anything about this case?
3. The lawyers and law firms involved in this case are:(See attached typed
list). Do any of you or your immediate families, such as spouse, child, parent, or
sibling, know any ofthe attorneys or law firms I have just named?
4. Have any of you or your immediate families had any business dealings
with, or been employed by, any ofthese attorneys or law firms?
5. Have any of you or your immediate families ever been employed by (List
all involved)( e.g. Safeguard, or Saints, or by Laureate Pharma,Inc., ofPrinceton,
New Jersey, or by Alliance Holdings, Inc., Alliance Global Services, Inc., or
Alliance Life Sciences, all of Abington, Pennsylvania?
6. Have any of you or your immediate families ever owned stock in any of
these companies?
7. Have any of you or your immediate families ever had a business
relationship with any ofthese companies?
8. Have any of you or your immediate families ever had any experience,
good or bad, with any ofthese companies,that might keep you from being a fair
and impartialjuror in this case?
9. Do you possess any opinions about any ofthese companies that might
keep you from being a fair and impartial juror in this case?
10. The potential witnesses in this case are:(See attached typed list). Are
you familiar with any ofthese potential witnesses?
11. Have you or any member of your immediate family ever been employed
by the United States Food & Drug Administration?
12. Have you or any member of your immediate family ever been employed
by a venture capital company?
13. Have you served as a juror in a civil lawsuit within the last fifteen(15)
years?
14. Have any of you, or your immediate families, taken a drug or medicine
that was
defective, impure or contaminated?
15. If you are selected to sit as a juror in this case, are you aware of any
reason why you would be unable to render a verdict based solely on the evidence
presented at trial?
16. If you are selected to sit as a juror in this case, are you aware of any
reason why you would not be able to follow the law as I give it to you?
17. Is there anything, such as poor vision, difficulty hearing, difficulty
understanding spoken or written English, that would make it difficult for you to
serve on this jury?
18. Have you previously been a party or a witness in a breach of contract
lawsuit?
19. This is the last question. Is there anything else, including something you
have remembered in connection with one ofthe earlier questions, that you think
you would like to tell me in connection with your service as a juror in this case?
