Augustine B. Jimenez III State Bar No. 012208 Montoya Jimenez, P.A. 3200 N. Central Avenue, Suite 2550 Phoenix, AZ 85012-2490 (602) 263-7875 [email protected] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Palma Baca Urrutia, et al., Plaintiffs, vs. Darrell Lee Ekdahl, et al., Defendants. ) CIV 03 1990 PHX PGR ) NO. ) ) PLAINTIFFS' PROPOSED ) FORMS OF VERDICT ) ) ) ) )
Pursuant to the Court's Order of November 22, 2005, Plaintiffs submit the following proposed forms of verdict. Respectfully submitted this 6 th day of March, 2006. MONTOYA JIMENEZ, P.A.
s/Augustine B. Jimenez III Augustine B. Jimenez III 3200 N. Central, Suite 2550 Phoenix, Arizona 85012 Attorneys for Plaintiffs /// /// /// ///
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FORM OF VERDICT NEGLIGENCE/NEGLIGENCE PER SE OF DARRELL LEE EKDAHL The jury must unanimously agree on the answers to the following questions:
1.
Has Plaintiff Palma Baca Urrutia proven any of her claims against Defendant Darrell Lee Ekdahl as defined by the Court's instructions? YES_________ NO_________
1(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
1(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
2.
Has Plaintiff Patricia Urrutia-Baca proven any of her claims against Defendant Darrell Lee Ekdahl as defined by the Court's instructions? YES_________ NO_________
2(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the
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Court's instructions--if any--Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________ 2(b). State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
3.
Has Plaintiff Luis Javier Urrutia-Baca proven any of his claims against Defendant Darrell Lee Ekdahl as defined by the Court's instructions? YES_________ NO_________
3(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
3(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
4.
Has Plaintiff Elizabeth Urrutia-Baca proven any of her claims against Defendant Darrell Lee Ekdahl as defined by the Court's instructions? YES_________ NO_________
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4(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
4(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
5.
Has Plaintiff Javier Arturo Urrutia-Arrieta proven any of his claims against Defendant Darrell Lee Ekdahl as defined by the Court's instructions? YES_________ NO_________
5(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
5(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
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6.
Has Plaintiff Gloria Estela Sandate proven any of her claims against Defendant Darrell Lee Ekdahl as defined by the Court's instructions? YES_________ NO_________
6(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
6(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Darrell Lee Ekdahl. AMOUNT $_____________________
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FORM OF VERDICT NEGLIGENT SUPERVISION BY VANDY'S TRANSPORTATION, INC. The jury must unanimously agree on the answers to the following questions:
7.
Has Plaintiff Palma Baca Urrutia proven any of her claims against Defendant Vandy's Transportation, Inc., as defined by the Court's instructions? YES_________ NO_________
7(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
7(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
8.
Has Plaintiff Patricia Urrutia-Baca proven any of her claims against Defendant Vandy's Transportation, Inc., as defined by the Court's instructions? YES_________ NO_________
8(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be
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awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________ 8(b). State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
9.
Has Plaintiff Luis Javier Urrutia-Baca proven any of his claims against Defendant Vandy's Transportation, Inc., as defined by the Court's instructions? YES_________ NO_________
9(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
9(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
10.
Has Plaintiff Elizabeth Urrutia-Baca proven any of her claims against Defendant Vandy's Transportation, Inc., as defined by the Court's instructions? YES_________ NO_________
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10(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
10(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
11.
Has Plaintiff Javier Arturo Urrutia-Arrieta proven any of his claims against Defendant Vandy's Transportation, Inc., as defined by the Court's instructions? YES_________ NO_________
11(a).
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
11(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
12.
Has Plaintiff Gloria Estela Sandate proven any of her claims against Defendant Vandy's Transportation, Inc., as defined
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by the Court's instructions? YES_________ 12(a). NO_________
If you answered "YES" to the preceding question, state the amount of compensatory damages as defined by the Court's instructions--if any--Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
12(b).
State the amount of punitive damages as defined by the Court's instructions--if any--that Plaintiff should be awarded against Defendant Vandy's Transportation, Inc. AMOUNT $_____________________
I hereby certify that on March 6, 2006, I electronically transmitted the foregoing document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Donald R. Wilson and S. Lee White. s/Augustine B. Jimenez III
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