Do you find from a preponderance of the evidence:
1. That [Plaintiff] had a “disability?”
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 a “qualified individual?”
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] knew of [Plaintiff]’s disability?
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] requested an accommodation?
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 a reasonable accommodation existed that would have allowed [Plaintiff] to perform the essential functions of the job?
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.
6. That [Defendant] failed to provide a reasonable accommodation?
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.
[7. That [Defendant] made good faith efforts to identify and make a reasonable accommodation for [Plaintiff]?
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.]20
[8. That [Plaintiff]’s requested accommodation would have imposed an undue hardship on the operation of [Defendant]’s business?
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.]
9. That [Plaintiff] should be awardeddamages to compensate for a net loss of wages and benefits to the date of your verdict?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
10. That [Plaintiff] should be awardeddamages to compensate for emotional pain and mental anguish?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
[If you did not awarddamages in response to either Question Nos. 9 or 10, this ends your deliberations, and your foreperson should sign and date the last page of this verdict form.
If you awardeddamages in response to Question Nos. 9 or 10 (or both), go to the next question.]
[11. That punitive damages should be assessed against [Defendant]?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
SO SAY WE ALL.