Do you find from a preponderance of the evidence:
1. That [Defendant] [discharged [Plaintiff] from employment/denied [Plaintiff] a promotion]?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “Yes,” go to the next question.
2. That [Plaintiff]’s [race/religion/sex/national origin] was a motivating factor that prompted [Defendant] to take that action?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “Yes,” go to the next question.
[3. That [Defendant] would have [discharged [Plaintiff] from employment/denied [Plaintiff] a promotion] even if [Defendant] had not taken [Plaintiff]’s [race/religion/sex/national origin] into account?
Answer Yes or No _____________
If your answer is “Yes,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “No,” go to the next question.]
4. That [Plaintiff] should be awardeddamages to compensate for a net loss of wages and benefits to the date of your verdict?
Answer Yes or No _____________11
If your answer is “Yes,” in what amount? $_____________
5. That [Plaintiff] should be awardeddamages to compensate for emotional pain and mental anguish?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
[If you did not awarddamages in response to either Question Nos. 4 or 5, this will end your deliberations, and your foreperson should go to the end of this verdict form to sign and date it.
If you awardeddamages in response to Question Nos. 4 or 5 (or both), go to the next question.]
6. That punitive damages should be assessed against [Defendant]?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
SO SAY WE ALL.