Free Appendix - District Court of Delaware - Delaware

' r Case 1:04-cv—00956-G|\/IS Document 196-4 Filed 06/19/2006 Page 1 Of 4
- IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CORPORAL B. KURT PRICE, et al., ) I
Plaintiffs, ) A . _
I v. i C.A. N0. 04-956 (GMS) A
) C.A. N0. 04-1207 (GMS)
COLONEL L. AARON CHAFFINCH, et al. )
V Defendants. ) I A
VERDICT FORM
A Wayne Warren v. Chaffinch, et al. I
I. D0 you find that the defendant took adverse action against Plaintiff Warren that was
sufficient to cause a reasonably hardy person to refrain from exercising his rights under the
i First Amendment? l
U (a) l Aaron Chaffinch Yes __f No ___
(b) Thomas MacLeish Yes QV; No ____
U you answered “Yes " to Question ] (a), proceed to Question 2(a).
U you answered "Yes "to Question 1 (Z2), proceed to Question 2(la).
H you answered "No " to both Questions 1 (a) and J (Z2), sign this verdict form and proceed .
to theiverdiet form for Plaintf F ora/cer. ·
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Y ` V Case 1:04-cv—00956-G|\/IS Document 196-4 Filed 06/19/2006 Page 2 of 4
2. Do you find that Plaintiff Warren has proven that his protected activity under the First A A
Amendment (speaking out about the conditions at the DSP indoor firing range) was a
substantial or motivating factor in the adverse action taken against him by the defendant?
(a) Aaron Chaftinch Yes ___{ No __
(b) Thomas MacLeish Yes __»{ No ___
H you answered "Yes" to Question 2(a), proceed to Question 3(tz).
H you answered "Yes" to Question 2(b), proceed to Question 3 (ZJ). -
K you answered "No "to both Questions 2(a) and 2(IJ), sign this verdictform and proceed
to the verdict form for Plainty‘j’Foraker. . =
3. Do you find that the defendant has proven by a preponderance ofthe evidence that he would
have taken the same action against Plaintiff Warren, even in the absence of Plaintiff
· Wairen’s exercise of his right to free speech? -
(a) Aaron Chaffinch Yes _g_ No __’< l V _
(b) Thomas MacLeish Yes ; No gf
Lf you answered “Y es "to both Questions 3(cz) and 3(bj, sign this verdict form and proceed l
to the verdict form for Plaintyf F ora/cer. . `
` 17 you answered '7\/o" to either Question 3(a) or 3(/J), proceed to Question 4.
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’ ’ Case 1:04-cv—00956-G|\/IS Document 196-4 Filed 06/19/2006 Page 3 of 4
- Damages - A ` V
_ 4. Was the adverse action taken against Plaintiff Warren by the defendant the proximate cause _ _
of any damage to him?
(a) Aaron Chafiineh Yes ____( No ___ .
(b) Thomas MacLeish Yes i No _____ A A _
l Kyou answered "Yes "to either Question 4 (aj or 4(Z2), proceed to Question 5. Q
H you answered "No" to both Questions 4(a) and 4(Z2), sign this verdict form and proceed l A
t to the verdict form for Plaintnf F ora/cer.
_5. What damages, if any, do you find that Plaintiff Warren suffered as a result of the adverse `A
action taken against him'?
(a) FrontPay QQ U
1 (b) Emotional Distress, Injury to Reputation, and Humiliation $ 52;OO · E A U
Proceed to Question 6. l
6. Do you find that Defendant Chaffinch acted recklessly, maliciously, or intentionally with U
regard totP1aintiff Warren? A
_ Yes J1 No ___
U you answered "Yes" to Question 6, proceed to Question 7.
K you answered "No" to Question 6, proceed to Question 8. E A in
7. If you answered "Yes" to Question 6 and you wish to exercise your discretion to award
punitive damages to Plaintiff Warren, enter below the amount of punitive damages which ·
you believe is appropriate to punish and deter Defendant Chaffinch. A
Amount of Punitive Damages: $ \ {2,2.5 `
U Proceed to Question 8. ·
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_ , Case 1 :04-cv-00956-GIVIS Document 196-4 Filed 06/19/2006 Page 4 of 4
. 8. Do you find that Defendant MacLeish acted recklessly, maliciously, or intentionally with
regard to Plaintiff Warren? I
Yes L No _____ I
IY you answered “Yes" to Question 8, proceed to Question 9. I A
lf you answered “No " to Question 8, sign-this verdict form and proceed to the verdict form _
for PZaint1]§’Foraker. _ . V ·
9. If you answered "Yes" to Question 8 and you wish to exercise your discretion to award n
punitive damages to Plaintiff Warren, enter below the amount of punitive damages which
you believe is appropriateito punish and deter Defendant MacLeish. 8
Amount of Punitive Damages: $ 2
this verdict form and proceed to the verdict form for Plaintyjé F oraker.
THE FOREGOING IS THE VERDICT THE JURY »
Q V EACH JUROR MUST SIGN BELOW
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