Set forth below are standard voir dire questions that the Court typically will ask during jury selection. Any variations or additions that the parties wish to make must be submitted in writing, in the format and under the schedule set forth in the Court's Standing Order on Preparation of Final Pretrial Order and Other Trial Preparation Materials.

General Voir Dire Questions (asked of the potential jurors as a group):

1. Is there anyone who because of medical or other important reasons cannot be available for the duration of the trial?

2. Is there anyone who suffers from any condition or situation that would make it difficult to give the parties your full attention and fair consideration if you were selected as a juror?

3. Is there anyone who has difficulty reading, writing or understanding the English language, so that it would impair your ability to understand what you hear in court or to read the documents that may be used as exhibits?

4. Is there anyone here who is related to, or knows, or has had dealings with any of the lawyers in the case; any of the plaintiff(s); any of the defendant(s); or the following people who may testify at trial?

5. Other than what you have heard in the brief description given today of the case, does anyone

know or has anyone heard anything about this case?

6. Is there anyone who has philosophical, religious or other beliefs that would prevent you from sitting and passing judgment on another person?

7. Is there anyone who believes there is something about the kind of case that I described to you that would prevent you from being fair and impartial to all parties in this case?

8. Is there anyone who believes that he or she would be unable to follow the law as I explain it to you, apply that law to the facts that you find in this case, and render the verdict required by the law as I explain it to you?

Individual Voir Dire Questions (asked of each juror individually):

1. Full name and age.

2. City of residence (and if Chicago, the area of Chicago).

3. Marital status.

4. Number and age of any children.

5. Extent of formal education.

6. Any legal training or experience.

7. Present occupation and any other employment going back 10 years, including name of employer(s), nature of work and title of position(s), and length of time with each employer.

8. Present occupation (and prior jobs going back 10 years) for spouse and other adults in the household, as well as for any adult children not living in the household.

9. Major outside interests and hobbies.

10. Military service, if any (including branch, years of service, highest rank achieved, duties, nature of discharge).

11. Prior jury service (federal and state civil and criminal cases, as well as grand jury).

12. Prior involvement as a party in any civil lawsuit (personally as well as in connection with any employment).

13. Prior involvement of relatives or close friends in any civil lawsuits.

14. Prior experience as a witness (in court hearing or deposition).