Do you find from a preponderance of the evidence:
1. That [Plaintiff] [was a member of/applied to be a member of/performed service in/applied to perform service in/had an obligation to perform service in] a uniformed service?
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] [discharged [Plaintiff] from employment/denied [Plaintiff] a promotion]?
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 [Plaintiff]’s [membership/application for membership/service/application for service/obligation for service] in a uniformed service was a motivating factor that prompted [Defendant] to take that 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] would have [discharged [Plaintiff] from employment/denied [Plaintiff] a promotion] even if [Defendant] had not taken [Plaintiff]’s [membership/application for membership/service/application for service/obligation for service] in a uniformed service into account?
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
5. 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? $_____________
If you did not awarddamages in response to Question No. 5, 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 No. 5, go to the next question.
6. That [Defendant] willfully violated the law?
Answer Yes or No _____________
SO SAY WE ALL.