SPECIAL INTERROGATORIES TO THE JURY

Do you find from a preponderance of the evidence:
1. That [Defendant] discharged [Plaintiff] from employment?
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 the discharge was without “just cause”?
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 [Union] breached its duty of fair representation owed to [Plaintiff] as one of its members?
Answer Yes or No _____________
4. That [Plaintiff] should be awarded damages?
Answer Yes or No _____________
If your answer is “Yes,” in what amount? $_____________
5. That [Plaintiff]’s damages should be divided between the defendants?
Answer Yes or No _____________
If your answer is “Yes,” how should they be divided?
_____________ % against [Defendant]

_____________ % against [Union]
SO SAY WE ALL.
DATE:
Foreperson’s Signature