Free Proposed Jury Instructions - District Court of Delaware - Delaware

Case 1 :04-cv-00861-JJF Document 37-2 Filed 05/03/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LYNN SANSOUCIE, :
Plaintiff, : Civil Action N0. 04-0861-JJF
v. :
REPRODUCTIV E ASSOCIATES oF
DELAWARE, P.A., :
Defendant.
DEFENDANT’S PROPOSED SPECIAL VERDICT
David H. Williams, Esquire (ID#616)
· Jennifer L. Brierley, Esquire (ID#407 5)
MORRIS, JAMES, PHTCHENS
& WILLIAMS LLP
222 Delaware Avenue, 10th Floor
Wilmington, DE 19801-1621
(302) 888-6800
[email protected]
itzrierl@[email protected];9m
Attomeys for Defendant
Dated; May 3, 2005

Case 1:04-cv-00861-JJF Document 37-2 Filed 05/03/2005 Page 2 of 4
SPECIAL VERDICT
As part of your deliberations, please answer the following questions:
LIABILITY
l. Do you find by a preponderance of the evidence that Ms. Sansoucie was
exempt from the overtime requirements of the Fair Labor Standards Act because she was
employed as a professional employee?
Yes
No
[Answer Questions No. 2 only if you answered "Yes" to Question No. 1.]
2. Do you find by a preponderance of the evidence that Reproductive
Associates’ violation of the FLSA was willful?
I Yes I A
No ____+
DAMAGES
[Answer Question No. 3A only if you answered "No" to Question No. 2.]
3A. What back pay do you award Ms. Sansoucie calculated from July 14, 2002
until the date of her resignation (i.e., February 4, 2004)?
Answer in dollars and cents $
[Answer Question No. 3B only if you answered "Yes" to Question No. 2.]
3B. What back pay do you award Ms. Sansoucie calculated from July 14, 2001
until the date of her resignation (i.e., February 4, 2004)?
Answer in dollars and cents $
JLB/016459-0003/1165085/1

Case 1:04-cv-00861-JJF Document 37-2 Filed 05/03/2005 Page 3 of 4
MORRIS, JAMES, HITCHENS
& WILLIAMS LLP
ga;d H. Wil1i§$s, Esquire (lD#616)
Jennifer L. Brier ey, Esquire (ID#4075)
222 Delaware Avenue, 10th Floor
Wilmington, DE 19801-1621
(302) 888-6800
dwilliams@morrisjamescom
jbrierley@morrisjamescom
Attorneys for Defendant
Dated: May 3, 2005
JLB/016459-0003/1165085/1

Case 1:04-cv-00861-JJF Document 37-2 Filed 05/03/2005 Page 4 of 4 V
CERTIFICATE OF SERVICE
I, Jennifer L. Brierley, hereby certify that on this 3rd day of May, 2005, I
caused to be served a true and correct copy of Defendant’s Proposed Special Verdict by
electronic delivery and mailto:
Jeffrey K. Martin
Margolis Edelstein
1509 Gilpin Avenue
Wilmington, DE 19806
Attorney for Plaintiff Lynn Sansoucie
{ /0 /
Jen ifer L. Bri y
11.12./016459-0003/1issoss/1