Free Appendix - District Court of Delaware - Delaware

' - 3 Case 1 :04-cv—00956-GIVIS Document 196-3 Filed 06/19/2006 Page 1 of 4 ‘
_ IN THE UNITED STATES DISTRICT COURT U .
FOR THE DISTRICT OF DELAWARE ,
CORPORAL B. KURT PRICE, et al., ) »
Plaintiffs, )
v. g C.A. N0. 04—956 (GMS) I
) C.A. N0. 04-1207 (GMS)
COLONEL L, AARON CHAFFINCH, et al. )
· _ Defendants. g ·
‘ VERDICT FORM 0
Kurt Price v. Chaffinch, et al. I
1. D0 you find that the defendant took adverse action against Plaintiff Price that was sufficient
to cause a reasonably hardy person to refrain from exercising his rights under the First
Amendment?
(a) Aaron Chaffinch Yes L No ___
(b) Thomas MacLeish Yes JL No ____
H you answered “Yes" to Question I (cz), proceed to Question 2(aj.
H you answered "Yes" to Question ] (lv), proceed to Question 2(Z1).
K you answered "No" to both Questions 1 (a) and Nb), sign this verdict form and proceed A
to the verdict form for Plaintyjf Warren. Q
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fa . -_ . Case 1 :04-cv-00956-GIVIS Document 196-3 Filed 06/19/2006 Page 2 of 4
2. Do you find that Plaintiff Price has proven that his protected activity under the First
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 Chaffinch Yes L4 No ___ gp
(b) Thomas MacLeish Yes No _____
. . H you answered "Yes "to Question 2(a), proceed to Question 3 (a).
U you answered “Yes" to Question 2(b), proceed to Question 3(Z2).
K you answered “No" to both Questions 2(a) and 2(Z2), sign this verdict form and proceed
to the verdict form for PlaintQ7 Warren. .
3. Do you find that the defendant has proven by a preponderance ofthe evidence that he would
have taken the same action against Plaintiff Price, even in the absence of Plaintiff Price’s i
exercise of his right to free speech? A
(a) Aaron Chaffinch Yes ____ No __'(
(b) Thomas MacLeish Yes ___ No Q5
H you answered “Y es "to both Questions 3(a) and 3(Z2), sign this verdict form and proceed
· to the verdict form for Plaintf Warren.
— U you answered "No" to either Question 3 (a) or 3 (Zi), proceed to Question 4.
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`I A Case 1:04-cv-00956-G|\/IS Document 196-3 Filed 06/19/2006 Page 3 of 4 .
Damages .
4, Was the adverse action taken against Plaintiff Price by the defendant the proximate cause of it
any damage to him?
P (a) Aaron Chaffineh Yes ___i{ A No ____
(b) Thomas MacLeish Yes __l/ No __
U you answered “Yes " to either Question 4(a) or 4(b), proceed to Question 5 ,
U you answered “No" to both Questions 4(a) and 4(b), sign this verdict form and proceed
to the verdict form for Plaintyf Warren,
5. Whatvdamages, if any, do you find that Plaintiff Price suffered as a result of the adverse
action taken against him?
A (a) Front Pay $ QD [QS
(b) Emotional Distress, Injury to Reputation, and Humiliation $ DILOO

Proceed to Question 6.
6. Do you find that Defendant Chaffincli acted recklessly, maliciously, or intentionally with
regard to Plaintiff Price? h All
Yes Qi No _____ l
P U you answered "Yes " to Question 6 proceed to Question 7.
H you answered “No" to Question 6, proceed to Question 8.
7. lf you answered "Yes" to Question 6 and you wish to exercise your discretion to award
punitive damages to Plaintiff Price, enter below the amount of punitive damages which you
believe is appropiiate to punish and deter Defendant Chaffinch.
Amount of Punitive Damages: $ 5
Proceed to Question 8. .
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‘ Case 1 :04-cv—00956-GIVIS Document 196-3 Filed 06/19/2006 Page 4 of 4
8. Do you find that Defendant MacLeish acted recklessly, maliciously, or intentionally with
regard to Plaintiff Price? U
Yes i No ___ I U
U you answered "Yes " to Question 8, proceed to Question 9. *
K you answered “No " to Question 8, sign this verdict form and proceed to the verdict form
for Plaintyf Warren. 8
9. If you answered "Yes" to Question 8 and you wish to exercise your discretion to award
punitive damages to Plaintiff Price, enter below the amount of punitive damages which you
believe is appropriate to punish and deter Defendant MacLeish. 7
· Amount ofPunitive Damages: $ 371 Q l 5
Sign this verdict form and proceed to the verdict form for Plaintyf Warren. .
THE FOREGOING IS THE VERDICT OF THE JURY
~ EACH JUROR MUST SIGN BELOW
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