Free Verdict Sheet - District Court of Delaware - Delaware

Case 1 :04-cv—00936-JJF Document 56 Filed 10/31 /2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOHN TURNER : CIVIL ACTION
AND
NANNETTE TURNER :
vs. :
B.V. SHIPPING COMPANY
LUZON STRAIT (GRONINGEN) : NO. 04-0936-JJF
PLAINTIFFS’ PROPOSED SPECIAL VERDICT FORM
Plaintiffs J olm and Nannette Turner request the Court to propound the following
special Verdict.
1. Was defendant B.V. Shipping Company Luzon Strait (Groningen), the owner
ofthe M/V "Luzon Strait, negligent?
YES:
NO:
(lf your answer to Question #1 is YES, proceed to Question #2. If your answer is
NO, return to the courtroom)
2. If so, was such negligence a legal cause of any injury and damages to the
plaintiff John Turner?
YES:
NO:
(If your answer to Question #2 is YES, proceed to Question #3. If your answer to
Question #2 is NO, return to the courtroom)
3. Was plaintiff John Turner guilty of some contributory negligence?
YES:
NO:
(If your answer to Question #3 is "NO", do not answer Question #4 and go to
Question #5. If your answer to Question #3 is "YES" then answer Question #4.)

Case 1:04-cv—00936-JJF Document 56 Filed 10/31/2005 Page 2 of 2 J
4. What part, if any, stated as a percentage, did plaintiff John Turner’s own
negligence play in causing his injury?
%
5. What amount do you find, without any reduction for any negligence that you
may find on plaintiff John Turner’s part, will fairly and adequately compensate plaintiff
John Turner for his injuries?
$
6. What amount do you find, without any reduction for negligence that you may
find on plaintiff John Turner’s part, will fairly and adequately compensate plaintiff
Nannette Turner for the loss of society of her husband John Turner?
$
Respectfully Submitted,
/S/ Stephen B. Potter
STEPHEN B. POTTER (ID# 298
POTTER, CARMINE, LEONARD &
AARONSEN
840 N. Union Street
Wilmington, DE 19805
/S/ Stanley B. Gruber
STANLEY B. GRUBER
FREEDMAN & LORRY, P.C.
400 Market Street, Suite 900
Philadelphia, PA 19106