Free Supplement - District Court of Arizona - Arizona

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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