Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:03-cv-01009-SRU

Document 128-6

Filed 04/07/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOSEPH ATTIAS & HAIM ATTIAS Plaintiffs : : : PATRONS MUTUAL INSURANCE COMPANY OF CONNECTICUT Defendant : : : APRIL 7, 2006 CIVIL NO. 3:03 CV 01009 (SRU)

PLAINTIFF'S PROPOSED JURY INTERROGATORIES 1. Do you, the jury, find that the defendant, Patrons, Mutual Insurance Company of

Connecticut breached its contract of insurance with the plaintiffs Haim Attias and Joseph Attias:

Yes.

No

2.

Do you, the jury, find that the defendant, Patrons Mutual Insurance Company of

Connecticut breached its duty of good faith and fair dealing with the plaintiffs, Haim Attias and Joseph Attias?

Yes

No

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3.

Do you, the jury, find that the defendant Patrons Mutual Insurance Company acted

in Bad Faith in the investigation or denial of the plaintiffs Haim Attias and Joseph Attias' claim?

Yes

No

4.

Do you, the jury, find that the defendant Patrons Mutual Insurance Company was

unjustly enriched by its denial of the plaintiff Haim Attias and Joseph Attias' claim? Yes No

5.

If responded YES to any of the Interrogatories numbered 1, 2, or 3, do you, the jury,

find that the defendant proved by a preponderance of the evidence that the plaintiffs Haim Attias and Joseph Attias willfully made intentional misrepresentations of material facts during the course of the investigation of the subject fire loss claim? Yes No

If you answered YES to this interrogatory then proceed to interrogatory 9

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6.

If you, the jury, responded YES to any of Interrogatories numbered 1, 2 or 3, and NO

to interrogatory number 5: Please set forth the damages you award the plaintiffs Haim Attias and Joseph Attias jointly;

Direct damages: Incidental damages: Consequential Damages: Interest:

Total Damages:

7.

If you, the jury, answered yes to interrogatory number 4 please set forth the amount

of damages you found the defendant was unjustly enriched:

8.

On the defendant's counterclaim, did you, the jury, find that the defendant canceled

or rescinded the contract of insurance between the parties? Yes No

If your answer to interrogatory number 8 is NO then skip interrogatory numbers 9 and 10. 9. If your answer to interrogatory number 8 is YES then: Did you, the jury, find that

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the plaintiffs were unjustly enriched by the defendant's payment to the mortgagee Ameriquest Mortgage? Yes No

If your answer to interrogatory number 9 is NO then skip interrogatory number 10.

10.

If you answer to interrogatory number 9 is YES then: What damages, if any, do you

find for the defendant?

Dated:

Signed: Foreperson Print Name:

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Case 3:03-cv-01009-SRU

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Filed 04/07/2006

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THE PLAINTIFFS,

BY: Cheryl E. Heffernan Farver & Heffernan 2858 Old Dixwell Avenue Hamden, Connecticut 06518 Telephone: 203-230-2500 Facsimile: 203-288-4702 Fed Bar No.: CT 06473

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