Free Jury Instructions - District Court of Arizona - Arizona

__w RECEIVED __ Copy
I James W. Field _
1>.o. nm; 248 JAN J 5 ZUU7
2 Salome, AZ. 85348 _
CLERK _tJ S DISTRICT CDDRT
, V DISTRICT es ARIZQNA
3 — }?l“"
4 IN THE UNITED STATES DISTRICT COURT
5 FOR THE DISTRIVCT OF ARIZONA, PHOENIX DIVISION
6
7 James W. Field, I ) Case No.: CV03-22l4-PHX-SRB
)
8 Plaintifi ) PLAINTIFFS' PURPOSED ADDITION T0
) JURY INSTRUCTIONS
9 vs. )
)
10 Brad Weekley et. al., )
)
ll Defendant )

12
I3 Comes now Plaintii}, requesting to include the Jury instruction 7.2 into Juries final
I4 instruction, to read as stated below.
I I5 In determining the measure of damages you should consider:
16 The nature and extent of the injuries suffered.
17
I8 l. The loss of the enjoyment of liberty, such as the Right to acquire and enjoy property the
19 Right to acquire useful knowledge, the Right to carry on business, the Right to earn
20 livelihood in any lawliil calling, the right to engage in a lawful business, to determine the
21 price of one’s labor and to tix the hours when one’s place of business shall be kept open,
22 The right to live and work where one will and the right to use property according to one’s
23 .. will,
24 2. The loss of income that have been experienced and which with reasonable probability will
I
25 be experienced in the iiiture.
I _l_
I Case 2:03-cv-02214-SRB Document 314 Filed O1/26/2007 Page 1 of 3

1 3. The mental, and emotional pain and suffering that has been suffered and that will continue
2 to su&`er in the future.
3 4. The reasonable value of potential Income experienced to this point and that with
4 reasonable probability will continue to experience in the future.
5 5. Refunded Rent to 45 migrant workers how left due to no electricity.
6 6. Loss of earning capacity and loss of inventory value.
7 7. Loss of property and its value.
8 8. Additional Expenses due to being forced to rent and office and a place to live.
9 9. Value of the ongoing business concern, (open more that a decade and now closed.
10 10. The embarrassment of having to barrow neighbors bathrooms for over 4 years
11 11. The emotional and Mental Anguish especially in a very small community.
12 12. The Cost of litigation stemming lrom the termination of power.
13 13. The extra cost of preparing and researching for the legal documents
1 14 14. The reasonable value of Plaintiffs diminished earning capacity
15 15. The reasonable value of the mental torment due to the possibility of losing 7.2 acres of
16 prime real estate and sole abode for 15 years.
17 Respectiiilly Submitted this Qfifday of January 13, 2007.
18 '
19 g Se Plaintiii James W. Field
20
21
22
23
24
25
Case 2:03-cv-02214-SRB Document 3i% Filed O1/26/2007 Page 2 of 3

1
2
ORIGINAL and One Copy of the foregoing
3 Filed this Q { day OfJ3.11l13.l'y 2007 with
4 Sandra Day O’Connor Federal Courthouse
Suite 130
5 401 W. Washington SLSPC1
6 Phx. AZ. 35003
A Copy oft e foregoing hand delivered
7 This day of January 2007 to
8 Jones, Skelton & Hochuli
9 2901 N. Central Ave.
Suite 800
10 Phx. AZ 12
By
H y Doud
12
13
14
15
16
. 17
18
19
20
21
22
23
24
25
Case 2:03-cv-02214-SRB Document 3T?4 Filed O1/26/2007 Page 3 of 3

Case 2:03-cv-02214-SRB

Document 314

Filed 01/26/2007

Page 1 of 3

Case 2:03-cv-02214-SRB

Document 314

Filed 01/26/2007

Page 2 of 3

Case 2:03-cv-02214-SRB

Document 314

Filed 01/26/2007

Page 3 of 3