Do you find from a preponderance of the evidence:
1. That [Plaintiff] had a “disability?”
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] was a “qualified individual?”
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] [describe adverse employment 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.
4. That [Defendant] took that action because of [Plaintiff]’s disability?
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.
5. 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? $_____________
6. 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. 5 or 6, 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. 5 or 6 (or both), go to the next question.]
[7. That punitive damages should be assessed against [Defendant]?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________]
SO SAY WE ALL.