Free Proposed Jury Instructions - District Court of Colorado - Colorado

Case 1:04-cv-01056-EWN-MEH

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Filed 02/08/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 04-cv-01056-EWN-OES

CONNIE J. REYNOLDS, Plaintiff, v. COBE CARDIOVASCULAR, INC., Defendant. ______________________________________________________________________________ DEFENDANT'S PROPOSED VERDICT FORM ______________________________________________________________________________

WE THE JURY, in the above-referenced action, render our verdict in response to the following questions: CLAIM 1: 1. RETALIATION UNDER THE ADEA

Do you find by a preponderance of the evidence that COBE Cardiovascular, Inc.

terminated the Plaintiff Connie J. Reynolds on September 9, 2003 because of her internal complaints of age discrimination in August 2003 and/or in her memo of September 8, 2003? _______ Yes ________ No

If you answered "Yes" to this question, then go to Question No. 2. If you answered "No" to this question, then you have found in favor of COBE Cardiovascular on this claim. Do not answer any more questions on this Claim and proceed to Claim 2.

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Case 1:04-cv-01056-EWN-MEH

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Filed 02/08/2006

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2.

What amount of economic damages did Plaintiff Connie J. Reynolds sustain as a

result of Defendant COBE Cardiovascular's decision to terminate her employment? $_______________

3.

Do you find by a preponderance of the evidence that the decision of Defendant

COBE Cardiovascular to terminate the Plaintiff was willful as defined in these instructions? _______ Yes ________ No

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Case 1:04-cv-01056-EWN-MEH

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Filed 02/08/2006

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CLAIM 2: 1.

RETALIATION UNDER TITLE VII

Do you find by a preponderance of the evidence that COBE Cardiovascular, Inc.

terminated the Plaintiff Connie J. Reynolds in September 2003 because of her internal complaints of sex discrimination in August 2003? _______ Yes ________ No

If you answered "Yes" to this question, then go to Question No. 2. If you answered "No" to this question, then you have found in favor of COBE Cardiovascular on this claim. You should proceed to the Certification section and you should not answer any more questions.

2.

Under the laws as given to you in these instructions, state the amount of

compensatory damages for non-economic losses, if any, Plaintiff Connie J. Reynolds should be awarded from Defendant COBE Cardiovascular. If you find that compensatory damages are not appropriate, check the box next to "(a)" and do not answer "(b)". a. b. ________ Compensatory damages should not be awarded. $_______ of compensatory damages should be awarded.

Proceed to the Certification.

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Case 1:04-cv-01056-EWN-MEH

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Filed 02/08/2006

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CERTIFICATION If you found a verdict for the Plaintiff on one or more of the claims, sign and date the following section. Once you have done so, inform the Court by note that you are ready to return to the courtroom to announce your verdict. By our signatures and our answers to these questions, we certify that we have found a verdict for Connie J. Reynolds, on the claim(s) indicated herein, and that the answers on this form represent the unanimous verdict of the jury.

Dated: ________________, 2006.

If you found a verdict for the Defendant on all of the claims, sign and date the following section. Once you have done so, inform the Court by note that you are ready to return to the courtroom to announce your verdict. By our signatures and our answers to these questions, we certify that we have found a verdict for COBE Cardiovascular, Inc. on all of the claims herein, and that the answers on this form represent the unanimous verdict of the jury.

Dated: ________________, 2006.

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