Free Proposed Verdict Form - District Court of Connecticut - Connecticut

Case 3:03-cv-01010-JBA

Document 60

Filed 01/31/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CECIL YOUNG, Plaintiff VS. CITY OF BRIDGEPORT HOUSING AUTHORITY, ET AL Defendants : : : : : : : : : : CIV. NO. 3:03CV1010 (JBA)

JANUARY 26, 2005

PLAINTIFF'S PROPOSED VERDICT FORM 1. Do you find by a preponderance of the evidence that the Plaintiff's actions in exercising his right of free speech pursuant to the First Amendment of the United States Constitution and Article First Section 4 of the Constitution of the State of Connecticut was a factor in the Defendant, City of Bridgeport's decision to terminate the Plaintiff? Yes ________________ No __________________

If your answer to Question No. 1 is Yes, then answer the next three questions. 2. What amount of damages did Plaintiff sustain as a result of the Defendant, City of Bridgeport's retaliation against him? Backpay Future pay _________________ _________________

Other Benefits _________________

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Case 3:03-cv-01010-JBA

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3. What amount of compensatory damages did Plaintiff sustain as a result of the Defendant, City of Bridgeport's retaliation? $ ____________________________ 4. Do you find by a preponderance of the evidence that the Plaintiff's retaliatory termination by the Defendant, City of Bridgeport, arose from some improper or unjustifiable motive or intent, or that the Defendant acted in reckless disregard of the Plaintiff's rights, or that the Defendant, City of Bridgeport, or Defendants acted in bad faith or acted wantonly? Yes _________________ No __________________

If your answer to Question No. 4 is Yes, then answer the next question. 5. What amount of punitive damages did Plaintiff sustain as a result of the Defendant, City of Bridgeport's retaliation? $ ____________________ 6. Do you find by a preponderance of the evidence that the Plaintiff's actions in exercising his right of free speech pursuant to the First Amendment of the United States Constitution and Article First Section 4 of the Constitution of the State of Connecticut was a factor in the Defendant, Bridgeport Housing Authority's decision to terminate the Plaintiff? Yes ________________ No __________________

If your answer to Question No. 6 is Yes, then answer the next three questions.

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Case 3:03-cv-01010-JBA

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7. What amount of damages did Plaintiff sustain as a result of the Defendant, Bridgeport Housing Authority's retaliation against him? Backpay Future pay _________________ _________________

Other Benefits _________________ 8. What amount of compensatory damages did Plaintiff sustain as a result of the Defendant, Bridgeport Housing Authority's retaliation? $ ____________________________ 9. Do you find by a preponderance of the evidence that the Plaintiff's retaliatory termination by the Defendant, Bridgeport Housing Authority, arose from some improper or unjustifiable motive or intent, or that the Defendant acted in reckless disregard of the Plaintiff's rights, or that the Defendant, Bridgeport Housing Authority, or Defendants acted in bad faith or acted wantonly? Yes _________________ No __________________

If your answer to Question No. 9 is Yes, then answer the next question. 10. What amount of punitive damages did Plaintiff sustain as a result of the Defendant, Bridgeport Housing Authority's retaliation? $ ____________________

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Case 3:03-cv-01010-JBA

Document 60

Filed 01/31/2005

Page 4 of 5

11. Do you find by a preponderance of the evidence that the Plaintiff's actions in exercising his right of free speech pursuant to the First Amendment of the United States Constitution and Article First Section 4 of the Constitution of the State of Connecticut was a factor in the Defendant, Collin Vice's decision to terminate the Plaintiff? Yes ________________ No __________________

If your answer to Question No. 11 is Yes, then answer the next three questions. 12. What amount of damages did Plaintiff sustain as a result of the Defendant, Collin Vice's retaliation against him? Backpay Future pay _________________ _________________

Other Benefits _________________ 13. What amount of compensatory damages did Plaintiff sustain as a result of the Defendant, Collin Vice's retaliation? $ ____________________________ 14. Do you find by a preponderance of the evidence that the Plaintiff's retaliatory termination by the Defendant, Collin Vice, arose from some improper or unjustifiable motive or intent, or that the Defendant acted in reckless disregard of the Plaintiff's rights, or that the Defendant, Collin Vice, or Defendants acted in bad faith or acted wantonly? Yes _________________ No __________________

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Case 3:03-cv-01010-JBA

Document 60

Filed 01/31/2005

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If your answer to Question No. 14 is Yes, then answer the next question. 15. What amount of punitive damages did Plaintiff sustain as a result of the Defendant, Collin Vice's retaliation? $ ____________________ THE PLAINTIFF BY:_____________________________ Thomas J. Weihing, Esq., ct 08235 Daly, Weihing & Bochanis 1115 Main Street, Suite 710 Bridgeport, CT 06604 (203) 333-8500 CERTIFICATION I hereby certify that a copy of the foregoing was mailed postage prepaid in this the 31 day of January, 2005 to:
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Barbara Brazzel-Massaro Associate City Attorney Office of the City Attorney 999 Broad Street Bridgeport, CT 06604 Michael T. Ryan, Esq. James Mahar, Esq. Ryan, Ryan, Johnson & Deluca, LLP 80 Fourth Street Stamford, CT 06905

______________________________ THOMAS J. WEIHING Commissioner of the Superior Court

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