Defendants' Revised Proposed Special Verdict Form (Page 2 of 6) in pdf

Defendants' Revised Proposed Special Verdict Form Page 2

Case 3:02-cv-01619-AWT

Document 42

Filed 01/16/2007

Page 2 of 6

[ ] YES

[ ] NO

2. If you answered "yes" to interrogatory no. B.1, then do you find that the unlawful

conduct on the part of the defendant, _______________ was the proximate cause of injury to the

plaintiff?

[ ] YES

[ ] NO

(If you answered "yes" to both interrogatories, you may go on to consider damages

against this defendant in Part III below.)

II. LIABILITY: - State Law Claims

A. Intentional Infliction of Emotional Distress as to Defendant _________________:

1. Do you find that the plaintiff has proven by a preponderance of the evidence that the

plaintiff was unlawfully subjected to the intentional infliction of emotional distress by defendant

__________________?

[ ] YES

[ ] NO

2. If you answered "yes" to interrogatory no. A.1, then do you find that the unlawful

conduct on the part of the defendant, _______________ was the proximate cause of injury to the

plaintiff?

B. Intentional Infliction of Emotional Distress as to Defendant _________________:

1. Do you find that the plaintiff has proven by a preponderance of the evidence that the

plaintiff was unlawfully subjected to the intentional infliction of emotional distress by defendant

__________________?

[ ] YES

[ ] NO

-2-

Defendants' Revised Proposed Special Verdict Form Page 2