Defendants' Revised Proposed Special Verdict Form (Page 4 of 6) in pdf

Defendants' Revised Proposed Special Verdict Form Page 4

Case 3:02-cv-01619-AWT

Document 42

Filed 01/16/2007

Page 4 of 6

1. Do you find that the plaintiff has proved actual damages suffered as the result of the

defendants' wrongdoing?

[ ] YES

[ ] NO

2. If you answered "yes" to interrogatory no. II.1, what amount of money in actual

damages is fair and just to compensate the plaintiff for the injuries inflicted upon him by the

defendants?

$ ___________________

3. If you answered "no" to interrogatory no. II.1, you have found that the plaintiff has

proved that the defendant, Perry Wilson or Robert Brennan, or both of them, violated his rights,

but that he failed to prove actual damages. You must, therefore award nominal damages in an

amount not to exceed $1.00. Enter that amount below.

$ ___________________

4. If you awarded either actual or nominal damages to the plaintiff in interrogatories II.2

or II.3 above, for false imprisonment in violation of his rights under the Fourth Amendment to

the U.S. Constitution, and keeping in mind the Court's instruction on punitive damages, do you

find that the defendant, ____________________ should be punished or deterred from future

misconduct by an award of punitive damages in addition to that already listed above?

[ ] YES

[ ] NO

5. What amount of punitive damages is fair and just in order to punish each defendant, or

to deter him/her from future misconduct?

As to defendant __________________

$ ______________

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Defendants' Revised Proposed Special Verdict Form Page 4