SPECIAL INTERROGATORIES TO THE JURY

Do you find from a preponderance of the evidence:
1. That [Plaintiff] engaged in protected activity?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.

If your answer is “Yes,” go to the next question.
2. That [Defendant] took an adverse employment action against [Plaintiff]?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.

If your answer is “Yes,” go to the next question.
3. That [Defendant] took the adverse employment action because of [Plaintiff]’s protected activity?
Answer Yes or No _____________
If your answer is “No,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.

If your answer is “Yes,” go to the next question.]
4. That [Plaintiff] suffered damages because of the adverse employment action?
Answer Yes or No _____________
[Insert damages interrogatories based on substantive charge damages interrogatories. For claims under Title VII, please see Pattern Instruction 4.5, supra. For claims under Section 1981, please see Pattern Instruction 4.9, supra. For claims under the ADEA, please see Pattern Instruction 4.10, supra. For claims under the ADA, please see Pattern Instruction 4.11, supra. For claims under the FLSA, please see Pattern Instruction 4.10, supra, and the accompanying annotations].
SO SAY WE ALL.
DATE:
Foreperson’s Signature