Free Judgment - District Court of Delaware - Delaware

. Case 1:04-cv—00956-Gl\/IS Document 186-3 Filed 06/15/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CORPORAL B. KURT PRICE, et al., )
Plaintiffs, g .
v. ) C.A. No. 04-956 (GMS) I
) C.A. N0. 04-1207 (GMS)
COLONEL L. AARON CHAFFINCH, et al. )
_ Defendants. )
VERDICT FORM
Wayne Warren v. Chafiinch, et al.
1. Do 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?
(a) Aaron Chaffinch Yes i` No ;
(b) Thomas MacLeish Yes _\{_ No _
K you answered “Yes" to Question 1(tz), proceed to Question 2(a).
If you answered “Yes" to Question 1(b), proceed to Question 2(Zv).
H you answered "No " to both Questions 1 (tz) and 1 (Za), sign this verdict form and proceed
to the verdict form for Plaintf F ora/cer.

. Case 1 :04-cv-00956-GIVIS Document 186-3 Filed 06/15/2006 Page 2 of 4
2. Do you find that Plaintiff Warren 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 Z No __
(b) Thomas MacLeish Yes _—{ No ___
H you answered "Yes" to Question 2(a), proceed to Question 3(a).
[f you answered “Yes" to Question 2(/J), proceed to Question 3 (b).
U you answered “No" to both Questions 2(a) and 2(h), sign this verdict form and proceed
to the verdict form for Plaintf F oraker.
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
Warren’s exercise of his right to free speech?
(a) Aaron Chaffinch Yes __ No 4 U
(b) Thomas MacLeish Yes ¥__ No Z
H you answered "Yes " to both Questions 3 (a) and 3(Z2), sign this verdict form and proceed
to the verdict form for Plaintqf F oraker.
H you answered “N0" to either Question 3(a) or 3 (Z2), proceed to Question 4.

Q Case 1 :04-cv—00956-GIVIS Document 186-3 Filed 06/15/2006 Page 3 of 4
Damages A
4. Was the adverse action taken against Plaintiff Warren by the defendant the proximate cause U
of any damage to him? A
(a) Aaron Chaffinch Yes 4 No __ .
(b) Thomas MacLeish Yes i No __ A
Q Lf you answered "Yes" to either Question 4(a) or 4(li), proceed to Question 5.
K you answered “No" to both Questions 4(a) and 4(b), sign this verdict form and proceed
to the verdict form for Plaintf F oraker.
_5. What damages, if any, do you find that Plaintiff Warren suffered as a result of the adverse
action taken against him?
(a) ProntPay $ Q 2b I
(b) Emotional Distress, lnjtuy to Reputation, and Humiliation $ A
Proceed to Question 6.
6. Do you find that Defendant Chaffinch acted recklessly, maliciously, or intentionally with
regard to Plaintiff Warren? U
Yes J No ___
U you answered "Yes" to Question 6, proceed to Question 7.
K you answered "No " to Question 6, proceed to Question 8.
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.
Amount of Punitive Damages: S \ X ), {[2..5
Proceed to Question 8.

H · Q Case 1 :04-cv—00956-GIVIS Document 186-3 Filed 06/15/2006 Page 4 of 4
8. Do you find that Defendant MacLeish acted recklessly, maliciously, or intentionally with
regard to Plaintiff Warren?
Yes [_ No ;
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 Plaintyjf F oraker. . ·
9. If you answered "Yes" to Question 8 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 MacLeish.
Amount of Punitive Damages: $ 2
Sign this verdict form and proceed to the verdict form for Plaintwf F oraker.
THE FOREGOIN G IS THE VERDICT OF THE JURY
1 EACH JUROR MUST SIGN BELOW I