Free Verdict Sheet - District Court of Delaware - Delaware

Case 1:04-cv-01394-GMS

Document 232

Filed 05/24/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CAPTAIN BARBARA L. CONLEY, Plaintiff, v. COLONEL L. AARON CHAFFINCH, in his individual capacity, Defendant. ) ) ) ) ) ) ) ) ) )

C.A. No. 04-1394-GMS

DEFENSE SPECIAL VERDICT INTERROGATORIES 1. Do you find that Barbara Conley was equally qualified or better qualified than Paul Eckrich for promotion to the rank of Major in March of 2003? _________ Yes _________ No If your answer to the above is yes, proceed to #2. If your answer is no, proceed to #3. 2. Do you find that Barbara Conley's gender was a substantial or motivating factor in defendant's decision not to promote her to the rank of Major in March of 2003? _________ Yes _________ No 3. Do you find that Barbara Conley was equally qualified or better qualified than R.L. Hughes for promotion to the rank of Major in November of 2003? _________ Yes _________ No If your answer to #3 above is "yes", proceed to #4. If your answer to #3 is "no", and you answered "yes" to #2, then proceed to #5. if your answer to #3 is "no", and you answered "no" to either #1 or #2, your deliberations are over.

Case 1:04-cv-01394-GMS

Document 232

Filed 05/24/2006

Page 2 of 2

4.

Do you find that Barbara Conley's gender was a substantial or motivating factor in defendant's decision not to promote her to the rank of Major in November of 2003? _________ Yes __________ No

If you answered "yes" to either #2 or #4 above, proceed to #5. If your answer to #2 and #4 was "no", your deliberations are over. 5. Did the plaintiff sustain any injury as a proximate result of the denial of a promotion to the rank of Major? __________ Yes __________ No If you have answered "yes" to #5, proceed to #6. If you answered "no" to #5, your deliberations are over. 6. What dollar amount will fairly compensate the plaintiff for any damages sustained? $___________

If you make an award of damages, go on to question #7. If not, you are finished. 7. Do you find that the defendant acted maliciously, intentionally, or recklessly toward the plaintiff? __________ Yes __________ No If your answer to #7 was yes, proceed to #8. If not, you are finished. 8. What amount of punitive damages, if any, would be appropriate to punish and deter the defendant? $__________.