Do you find from a preponderance of the evidence:
1. That [Plaintiff] and a member, or members, of the opposite sex have been employed by [Defendant] in jobs requiring substantially equal skill, effort, and responsibility?
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 two jobs are performed under similar working conditions?
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 [Plaintiff] was paid a lower wage than a member of the opposite sex doing equal work?
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 the differential in pay between the two jobs was the result of a [seniority system/merit system/system measuring earnings by quantity or quality of production/describe factor other than gender upon which [Defendant] relies]?
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 [Defendant] either knew or showed reckless disregard for whether [his/her/its] conduct was prohibited by the Equal Pay Act?
Answer Yes or No _____________
6. That [Plaintiff] should be awardeddamages for lost compensation?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
SO SAY WE ALL.