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1 SHOOK HARDY & BACON LLP
Alicia J. Donahue (SBN: 117412)
2 adonahue@shb.com
3 Kara M. Flageollet (SBN: 347646)
kflageollet@shb.com
4 555 Mission Street, Suite 2300
San Francisco, CA 94105
5 Telephone: (415) 544-1900
6 Mayela C. Montenegro-Urch (SBN: 304471)
mmontenegro@shb.com
7 Jamboree Center
5 Park Plaza, Suite 1600
8 Irvine, CA 92614
9 Telephone: (949) 475-1500
10 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
Manuel Cachán (SBN: 216987)
11 manuel.cachan@skadden.com
300 South Grand Avenue, Suite 3400
12 Los Angeles, California 90071
Telephone: (213) 687-5000
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14 SIDLEY AUSTIN LLP
Jennifer Saulino (pro hac vice)
15 jennifer.saulino@sidley.com
1501 K Street, N.W.
16 Washington, D.C. 20005
Telephone: (202) 736-8000
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18 Attorneys for Defendant
Monsanto Company
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SONOMA
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Michael Meyer and Bobbie Meyer, Case No. SCV-269068
22 Assigned for all purposes to
Plaintiff, Hon. Christopher M. Honigsberg
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v. Defendant Monsanto Company’s Proposed
24 Preliminary Jury Questions
Monsanto Company, et al.
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Defendants. Complaint Filed: August 16, 2021
26 Trial Date: February 9, 2024
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DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS
1 Defendant Monsanto Company’s Proposed Preliminary Jury Questions
2 Pursuant to Section A(1)(a) of the March 2, 2023 Trial Orders of Court, Defendant
3 Monsanto Company’s Proposed Preliminary Jury Questions is attached hereto.
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Dated: February 1, 2024 SHOOK HARDY & BACON LLP
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/s/
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Alicia J. Donahue
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Counsel for Defendant
9 Monsanto Company
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DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS
1 Proposed Preliminary Jury Questions
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3 1. This is the start of the jury selection process. We will continue jury selection on
4 [DATE] and [DATE]. If you are selected to serve on this jury, you will be expected to
5 be in Court Tuesday through Friday, from 8:30 am until 1:30 pm. Trial is expected to
6 conclude by March 29th.
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8 While service on a jury is inconvenient, it is essential to our system of justice that we have
9 a representative cross-section of the community. Jury Service is both a requirement and
10 privilege of citizenship in this country. Please raise your hand if you believe your service
11 as a juror in this case would create (1) an undue or extreme physical hardship, (2) a
12 financial hardship on you or your dependents, or (3) a childcare problem for which you
13 have no workable solution.
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15 2. The Plaintiffs in this case are: Michael Meyer, Sr. and Bobbie Meyer. Please raise your
16 hand if you know or otherwise recognize any of the Plaintiffs.
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18 3. The Plaintiffs are represented by the following lawyers: Behram Parekh of Rueb Stoller
19 Daniel LLP, Brian Glasser of Bailey Glasser LLP, and David Wool of Wool Trial Law
20 LLC. Please raise your hand if you know or otherwise recognize any of the Plaintiffs’
21 lawyers or their firms.
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23 4. The Defendant in this case is Monsanto Company. Please raise your hand if you or a
24 family member currently work or have worked in the past for Monsanto Company.
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5. The Defendant is represented by the following lawyers: Jennifer Saulino of Sidley Austin
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LLP and Manuel Cachán of Skadden, Arps, Slate, Meagher & Flom LLP. Please raise your
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hand if you know or otherwise recognize any of the Defendant’s lawyers or their firms.
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DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS
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2 6. Please raise your hand if you hold any opinions about the safety of Monsanto’s
3 Roundup Weedkiller.
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5 7. Please raise your hand if you hold any opinions one way or the other about Monsanto.
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DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS
Michael Meyer and Bobbie Meyer v. Monsanto Company, et al.
Sonoma County Superior Court, Case No. SCV-269068
1 PROOF OF SERVICE
2 I am over eighteen years of age and not a party to this action. I am employed in the
county where this service occurs. My business address is 555 Mission Street, Suite 2300, San
3 Francisco, California 94105.
4 On February 1, 2024 a true and correct copy of the foregoing document entitled
Defendant Monsanto Company’s Proposed Preliminary Jury Questions will be served or was
5 served in the manner stated below:
6  By Mail (CCP § 1013.a, et seq.): I enclosed said document(s) in a seal envelope or package
7 to each addressee listed below. I placed said envelope for collection and mailing, following our
ordinary business practices. I am readily familiar with the firm’s practice of collection and
8 processing correspondence for mailing. On the same day that correspondence is placed for
collection and mailing, it is deposited in the ordinary course of business with the U.S. postal
9 service with postage fully prepaid.
10  By Electronic Service (E-mail) (CRC § 2.251(c)(3)):
11  I caused the document(s) to be sent to each addressee’s email address as set forth below or
on the attached service list. I did not receive, within a reasonable time after the transmission, any
12 electronic message or other indication that the transmission was unsuccessful.
PLEASE SEE ATTACHED SERVICE LIST
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 I caused the document(s) to be served upon the above-interested party(ies) using a court
14 approved electronic filing service provider to the electronic service address.
15  By Overnight Delivery (CCP §§ 1013(c)(d), et seq.: I enclosed said document(s) in a sealed
envelope or package provided by an overnight delivery carrier to the following address(es). I
16 placed the envelope or package, delivery fees paid for, for collection and overnight delivery at our
17 office for pick up by the carrier on the same day.
 State I declare under penalty of perjury under the laws of the State of California that the
18 foregoing is true and correct.
19  Federal I declare that I am employed in the office of a member of the bar of this court at
whose direction this service was made.
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Dated: February 1, 2024
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PROOF OF SERVICE
Michael Meyer and Bobbie Meyer v. Monsanto Company, et al.
Sonoma County Superior Court, Case No. SCV-269068
1 SERVICE LIST
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Behram V. Parekh Counsel for Plaintiffs
3 RUEB STOLLER DANIEL LLP
515 S Figueroa St, Ste 1550
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Los Angeles, CA 90071
5 behram.parekh@lawrsd.com
felice.wortman@lawrsd.com
6 luis.quinonez@lawrsd.com
7 David J. Wool
WOOD TRIAL LAW LLC
8 1001 Bannock St. #410
Denver, CO 80204
9 david@wooltriallaw.com
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Brian Glasser
11 BAILEY GLASSER LLP
1055 Thomas Jefferson Street NW
12 Suite 540,
Washington DC 20007
13 BGlasser@baileyglasser.com
14 David Selby
15 BAILEY GLASSER LLP
3000 Riverchase Galleria, Suite 905,
16 Birmingham AL 35244
DSelby@baileyglasser.com
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David Todd Mathews
18 BAILEY GLASSER LLP
210 W. Division St., Suite 2,
19 Maryville, IL 62062
tmathews@baileyglasser.com
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DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS
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1 SHOOK HARDY & BACON LLP Alicia J. Donahue (SBN: 117412) 2 adonahue@shb.com 3 Kara M. Flageollet (SBN: 347646) kflageollet@shb.com 4 555 Mission Street, Suite 2300 San Francisco, CA 94105 5 Telephone: (415) 544-1900 6 Mayela C. Montenegro-Urch (SBN: 304471) mmontenegro@shb.com 7 Jamboree Center 5 Park Plaza, Suite 1600 8 Irvine, CA 92614 9 Telephone: (949) 475-1500 10 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP Manuel Cachán (SBN: 216987) 11 manuel.cachan@skadden.com 300 South Grand Avenue, Suite 3400 12 Los Angeles, California 90071 Telephone: (213) 687-5000 13 14 SIDLEY AUSTIN LLP Jennifer Saulino (pro hac vice) 15 jennifer.saulino@sidley.com 1501 K Street, N.W. 16 Washington, D.C. 20005 Telephone: (202) 736-8000 17 18 Attorneys for Defendant Monsanto Company 19 SUPERIOR COURT OF THE STATE OF CALIFORNIA 20 COUNTY OF SONOMA 21 Michael Meyer and Bobbie Meyer, Case No. SCV-269068 22 Assigned for all purposes to Plaintiff, Hon. Christopher M. Honigsberg 23 v. Defendant Monsanto Company’s Proposed 24 Preliminary Jury Questions Monsanto Company, et al. 25 Defendants. Complaint Filed: August 16, 2021 26 Trial Date: February 9, 2024 27 28 DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS 1 Defendant Monsanto Company’s Proposed Preliminary Jury Questions 2 Pursuant to Section A(1)(a) of the March 2, 2023 Trial Orders of Court, Defendant 3 Monsanto Company’s Proposed Preliminary Jury Questions is attached hereto. 4 Dated: February 1, 2024 SHOOK HARDY & BACON LLP 5 6 /s/ 7 Alicia J. Donahue 8 Counsel for Defendant 9 Monsanto Company 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS 1 Proposed Preliminary Jury Questions 2 3 1. This is the start of the jury selection process. We will continue jury selection on 4 [DATE] and [DATE]. If you are selected to serve on this jury, you will be expected to 5 be in Court Tuesday through Friday, from 8:30 am until 1:30 pm. Trial is expected to 6 conclude by March 29th. 7 8 While service on a jury is inconvenient, it is essential to our system of justice that we have 9 a representative cross-section of the community. Jury Service is both a requirement and 10 privilege of citizenship in this country. Please raise your hand if you believe your service 11 as a juror in this case would create (1) an undue or extreme physical hardship, (2) a 12 financial hardship on you or your dependents, or (3) a childcare problem for which you 13 have no workable solution. 14 15 2. The Plaintiffs in this case are: Michael Meyer, Sr. and Bobbie Meyer. Please raise your 16 hand if you know or otherwise recognize any of the Plaintiffs. 17 18 3. The Plaintiffs are represented by the following lawyers: Behram Parekh of Rueb Stoller 19 Daniel LLP, Brian Glasser of Bailey Glasser LLP, and David Wool of Wool Trial Law 20 LLC. Please raise your hand if you know or otherwise recognize any of the Plaintiffs’ 21 lawyers or their firms. 22 23 4. The Defendant in this case is Monsanto Company. Please raise your hand if you or a 24 family member currently work or have worked in the past for Monsanto Company. 25 5. The Defendant is represented by the following lawyers: Jennifer Saulino of Sidley Austin 26 LLP and Manuel Cachán of Skadden, Arps, Slate, Meagher & Flom LLP. Please raise your 27 hand if you know or otherwise recognize any of the Defendant’s lawyers or their firms. 28 -3- DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS 1 2 6. Please raise your hand if you hold any opinions about the safety of Monsanto’s 3 Roundup Weedkiller. 4 5 7. Please raise your hand if you hold any opinions one way or the other about Monsanto. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS Michael Meyer and Bobbie Meyer v. Monsanto Company, et al. Sonoma County Superior Court, Case No. SCV-269068 1 PROOF OF SERVICE 2 I am over eighteen years of age and not a party to this action. I am employed in the county where this service occurs. My business address is 555 Mission Street, Suite 2300, San 3 Francisco, California 94105. 4 On February 1, 2024 a true and correct copy of the foregoing document entitled Defendant Monsanto Company’s Proposed Preliminary Jury Questions will be served or was 5 served in the manner stated below: 6  By Mail (CCP § 1013.a, et seq.): I enclosed said document(s) in a seal envelope or package 7 to each addressee listed below. I placed said envelope for collection and mailing, following our ordinary business practices. I am readily familiar with the firm’s practice of collection and 8 processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the U.S. postal 9 service with postage fully prepaid. 10  By Electronic Service (E-mail) (CRC § 2.251(c)(3)): 11  I caused the document(s) to be sent to each addressee’s email address as set forth below or on the attached service list. I did not receive, within a reasonable time after the transmission, any 12 electronic message or other indication that the transmission was unsuccessful. PLEASE SEE ATTACHED SERVICE LIST 13  I caused the document(s) to be served upon the above-interested party(ies) using a court 14 approved electronic filing service provider to the electronic service address. 15  By Overnight Delivery (CCP §§ 1013(c)(d), et seq.: I enclosed said document(s) in a sealed envelope or package provided by an overnight delivery carrier to the following address(es). I 16 placed the envelope or package, delivery fees paid for, for collection and overnight delivery at our 17 office for pick up by the carrier on the same day.  State I declare under penalty of perjury under the laws of the State of California that the 18 foregoing is true and correct. 19  Federal I declare that I am employed in the office of a member of the bar of this court at whose direction this service was made. 20 Dated: February 1, 2024 21 22 23 24 25 26 27 28 -1- PROOF OF SERVICE Michael Meyer and Bobbie Meyer v. Monsanto Company, et al. Sonoma County Superior Court, Case No. SCV-269068 1 SERVICE LIST 2 Behram V. Parekh Counsel for Plaintiffs 3 RUEB STOLLER DANIEL LLP 515 S Figueroa St, Ste 1550 4 Los Angeles, CA 90071 5 behram.parekh@lawrsd.com felice.wortman@lawrsd.com 6 luis.quinonez@lawrsd.com 7 David J. Wool WOOD TRIAL LAW LLC 8 1001 Bannock St. #410 Denver, CO 80204 9 david@wooltriallaw.com 10 Brian Glasser 11 BAILEY GLASSER LLP 1055 Thomas Jefferson Street NW 12 Suite 540, Washington DC 20007 13 BGlasser@baileyglasser.com 14 David Selby 15 BAILEY GLASSER LLP 3000 Riverchase Galleria, Suite 905, 16 Birmingham AL 35244 DSelby@baileyglasser.com 17 David Todd Mathews 18 BAILEY GLASSER LLP 210 W. Division St., Suite 2, 19 Maryville, IL 62062 tmathews@baileyglasser.com 20 21 22 23 24 25 26 27 28 -2- DEFENDANT MONSANTO COMPANY’S PROPOSED PRELIMINARY JURY QUESTIONS