Do you find from a preponderance of the evidence:
1. That [Plaintiff]’s supervisor harassed [Plaintiff] because of [his/her] [race/religion/sex/national origin]?
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 the harassment created a hostile work environment for [Plaintiff]?
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] exercised reasonable care to prevent and promptly correct any harassing behavior in the workplace because of [race/religion/sex/national origin]?
Answer Yes or No _____________
If your answer is “Yes,” go to the next question.
If your answer is “No,” go to Question No. 5.
4. [That [Plaintiff] unreasonably failed to take advantage of the preventive or corrective opportunities [Defendant] provided to avoid or correct the harm.] [That [Plaintiff] took advantage of the preventive or corrective opportunities provided by [Defendant] and [Defendant] responded by taking reasonable and prompt corrective action].
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.]
5. That [Plaintiff] suffered damages because of the hostile work environment
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.
6. 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 _____________
If your answer is “Yes,” in what amount? $_____________
7. 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. 6 or 7, this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If you awardeddamages in response to Question Nos. 6 or 7 (or both), go to the next question.]
[8. That punitive damages should be assessed against [Defendant]?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________]
SO SAY WE ALL.