Free Verdict Sheet - District Court of Delaware - Delaware

Case 1:06-cv-00725-GMS

Document 57

Filed 03/31/2008

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UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE KENNETH S. MITCHELL, Plaintiff, v. WACHOVIA CORPORATION, t/a WACHOVIA SECURITIES, WACHOVIA SECURITIES, L.L.C., WACHOVIA SERVICES, INC., WACHOVIA BANK OF DEL., N.A., TODD D. GAUTHIER, CAROLYN J. BEAM, and DOROTHY A. DIFEBO, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

C.A. No. 06-725 (GMS) JURY TRIAL DEMANDED

PLAINTIFF'S PROPOSED SPECIAL JURY INTERROGATORIES AND VERDICT FORM 1. Do you find by a preponderance of the evidence that any of the defendants created a hostile work environment for plaintiff Kenneth S. Mitchell, engaged in discrimination against him with respect to his race or gender, or retaliated against him for his complaints (please check box with your answer)? Yes No If you answered "Yes" above, please proceed to question number 2. If you answered "No" above, please stop and call the Bailiff. 2. If you answered "Yes" to question 1 above, please check the following box or boxes corresponding to the defendants whom you find liable to plaintiff (continued onto next page): Wachovia Corporation t/a Wachovia Securities Wachovia Securities, L.L.C. Wachovia Bank of Delaware, N.A. Wachovia Services, Inc. 1

Case 1:06-cv-00725-GMS

Document 57

Filed 03/31/2008

Page 2 of 2

Todd D. Gauthier Carolyn J. Beam Dorothy A. DiFebo 3. State the amount that you award to plaintiff Kenneth S. Mitchell for compensatory damages which may include emotional distress, past and future lost earnings, and medical expense reimbursement: Compensatory Damages 4. $_____________________

Do you find that any of the defendants whom you have found liable acted with malice or reckless indifference to plaintiff Kenneth S. Mitchell's federally protected rights? Yes No If you answered "Yes" to the above question, please state the amount that you award to plaintiff Kenneth S. Mitchell for punitive damages: Punitive Damages $_____________________

If you answered "No" to the above question, or after you have filled in the above blank amount, please stop and call the Bailiff.

SO WE ALL SAY, ____________________________ Foreperson May ____, 2008

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