Free Response - District Court of Connecticut - Connecticut

Case 3:01-cv-01979-WWE

Document 74-4

Filed 05/19/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT KARL HOGFELDT v. OLD SAYBROOK POLICE DEPARTMENT; ET AL : : : : : : NO.: 3:01CV1979 (WWE)

MAY 17, 2005

DEFENDANTS' PROPOSED SPECIAL VERDICT FORM

1. Do you find by a preponderance of the evidence that SERGEANT HULL committed assault and battery upon the plaintiff without justification? Yes _____ No _____ 2. Do you find by a preponderance of the evidence that SERGEANT HULL violated KARL HOGFELDT's Fourth Amendment right to be free from excessive force? Yes _____ No _____ 3. Do you find by a preponderance of the evidence that OFFICER DEMARCO committed assault and battery upon the plaintiff without justification? Yes _____ No _____ 4. Do you find by a preponderance of the evidence that OFFICER DEMARCO violated KARL HOGFELDT's Fourth Amendment right to be free from excessive force? Yes _____ No _____ 5. Do you find by a preponderance of the evidence that OFFICER PERROTTI committed assault and battery upon the plaintiff without justification? Yes _____ No _____ 6. Do you find by a preponderance of the evidence that OFFICER PERROTTI violated KARL HOGFELDT's Fourth Amendment right to be free from excessive force? Yes _____ No _____ 7. Do you find by a preponderance of the evidence that OFFICER RANKIN committed assault and battery upon the plaintiff without justification? Yes _____ No _____ 8. Do you find by a preponderance of the evidence that OFFICER RANKIN violated KARL HOGFELDT's Fourth Amendment right to be free from excessive force? Yes _____ No _____

Page 1 of 2

Case 3:01-cv-01979-WWE

Document 74-4

Filed 05/19/2005

Page 2 of 2

Only if you have answered yes to at least one of questions 2, 4, 6, and/or 8, you may consider question 10. Otherwise, if you answered yes to any question 18, go to 11. 10. Do you find by a preponderance of the evidence that the TOWN OF OLD SAYBROOK had a persistent or widespread policy, custom, pattern or practice of police officers using unreasonable force and that persistent or widespread policy, custom, pattern or practice caused a deprivation of KARL HOGFELDT's constitutional rights? Yes _____ No _____

11. Which of the following damages do you find the plaintiffs have proved by the preponderance of the evidence and how much do you award? Economic Damages Non-Economic Damages Punitive damages TOTAL _______________________ _______________________ _______________________ _______________________

_________________ DATE

_____________________________ FOREPERSON

Page 2 of 2