Do you find from a preponderance of the evidence:
[1. That [Plaintiff] was [Defendant]’s employee?
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 [Plaintiff] was at least 40 years old at the time of the [describe adverse employment action]?
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] [describe adverse employment action]?
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 [Defendant] took that action because of [Plaintiff]’s age?
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.
[5. That [age is a bona-fide occupational qualification] [[Defendant]’s seniority system used employees’ length of service and not the age of employees as the primary basis for giving available job opportunities to the employees]?
Answer Yes or No _____________
If your answer is “No,” go to Question No. 7.
If your answer is “Yes,” go to the next question.
6. That [[Defendant] took the action you found it took because of the bona-fide occupational age qualification/[Defendant]’s decision to take the action you found it took was consistent with [Defendant]’s seniority system]?
Answer Yes or No _____________
If your answer is “Yes,” this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If your answer is “No,” go to the next question.
7. That [Plaintiff] should be awardeddamages?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
[8. That [Defendant] willfully violated the law?
Answer Yes or No _____________]
SO SAY WE ALL.