Free Verdict Sheet - District Court of Delaware - Delaware

Case 1 :04-cv—00936-JJF Document 54 Filed 10/28/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOHN TURNER, et al :
: CIVH. ACTION
v. NO. 04-cv-0936 (JJF)
B.V. SHIPPING COMPANY LUZON
STRAIT (GRONINGEN) :
DEFENDANT’S PROPOSED JURY QUESTIONNAIRE
Directions: Your answer to each question must be unanimously decided by the jury. Please
follow the directions as stated.
QUESTION NO. 1 : Was plaintiff John Turner’s alleged accident caused solely by the
negligence of the stevedore employer, Delaware River Stevedores, Inc., the negligence of
plaintiff John Turner or the negligence of any of plaintiff s fellow Delaware River Stevedores,
Inc. employees?
ANSWER : Yes No
If you answered Question No. l with a "Yes" do not answer any further questions.
QUESTION NO. 2 : Did the Defendant B.V. Shipping Company Luzon Strait
(Groningen), owner of the M/V LUZON STRAIT, negligently breach the turnover duty?
ANSWER : Yes No
If you answered Question No. 2 with a "Yes" proceed to Question No. 3. If you answered
Question No. 2 with a "No" do not answer any further questions.

Case 1:04-cv—00936-JJF Document 54 Filed 10/28/2005 Page 2 of 3
QUESTION NO. 3 : Was the breach of the turnover duty by Defendant B.V. Shipping
Company Luzon Strait (Groningen), owner of the M/V LUZON STRAIT, a legal cause of any
injury to plaintiffs?
ANSWER : Yes: No
If you answered Question No. 3 with a "Yes" proceed to Question No. 4. If you answered
Question No. 3 with a "No" do not answer any further questions.
QUESTION NO. 4 : Was plaintiff John Turner guilty of some contributory negligence?
ANSWER : Yes: No
If you answered Question N0. 4 with a "No" do not answer Question No. 5 and go to Question
No. 6; but if your answer to Question No. 4 is "Yes" then answer Question No. 5.
QUESTION NO. 5 : VVhat degree (stated as a percentage) did John Tumer’s own
negligence play in causing his injuries?
ANSWER : %
Go on to Question No. 6.
QUESTION NO. 6 : What amount do you find will fairly and adequately compensate the
plaintiffs for the injuries that they sustained? (do not make a deduction based on any percentage
of negligence attributed to John Turner here).
ANSWER : $
PB111 179264.1 ·
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Case 1:04-cv—00936-JJF Document 54 Filed 10/28/2005 Page 3 of 3
Respectfully submitted,
PALMER BIEZUP & HENDERSON LLP
By: /s/ Michael B. McCauley
Michael B. McCauley, Esq. (ID # 2416)
Attorneys for Defendant,
B.V. Shipping Company Luzon Strait (Groningen)
1223 Foulk Road
Wilmington, DE 19803
(302) 594-0895
Of Counsel:
Richard Q. Whelan, Esq.
Palmer Biezup & Henderson LLP
956 Public Ledger Building
620 Chestnut Street
Philadelphia, PA 19106-3409 Dated: October 28, 2005
1>1;11; 179264.1 ‘
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