Free Proposed Jury Instructions/Request to Charge - District Court of Connecticut - Connecticut

Case 3:00-cv-00935-SRU

Document 67

Filed 03/18/2004

Page 1 of 4

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SONDRA MILLS Plaintiff, V. STATE OF CONNECTICUT JUDICIAL DEPARTMENT, Defendant. : CIVIL NO. 3:00CV935 (SRU) : : : : : : : : :

DEFENDANTS'S REVISED PROPOSED JURY VERDICT FORM

1.

Did plaintiff Sondra Mills prove that a she was qualified for the position of Caseflow Coordinator in GA 6 in 1999.

Yes _____

No______.

If you have answered Yes to Question 1, please proceed to Question 2. If you have answered No, please proceed to question 3.

2. Did plaintiff Sondra Mills prove that defendant State of Connecticut, Judicial Department, intentionally discriminated against her, in that her race was a motivating and determining factor, in the decision not to promote her to the position of Caseflow Coordinator of GA 6 in 1999?

Yes _____

No______.

Case 3:00-cv-00935-SRU

Document 67

Filed 03/18/2004

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3. Did plaintiff Sondra Mills prove that defendant State of Connecticut, Judicial Department, intentionally discriminated against her, in that her race was a motivating and determining factor, in the decision not to promote her to the position of Deputy Clerk of GA 6 in 1999?

Yes _____

No______.

If the answer to question 3, and EITHER question 1 or 2 is No, your deliberations are at an end. The foreperson should sign and date this form and notify the marshal that you have reached your verdict. The verdict will then be returned to Court. If the answer to either question 2 or question 3 is Yes, proceed to question 4.

4.

Did the plaintiff Sondra Mills prove by a preponderance of the evidence that she suffered damages, excluding any damages relating to wages or retirement benefits, that were causally related to her failure to promote claims. Yes _____ No _____

Case 3:00-cv-00935-SRU

Document 67

Filed 03/18/2004

Page 3 of 4

5.

If the answer to question 4 is Yes, what, if any, amount of money did plaintiff Sondra Mills prove will fairly and reasonably compensate her for her damages, again damages, excluding any damages relating to wages or retirement benefits? $ ____________

6.

If plaintiff Sondra Mills has failed to prove actual damages, then do you find an award of one dollar in nominal damages appropriate? Yes _____ No _____

Case 3:00-cv-00935-SRU

Document 67

Filed 03/18/2004

Page 4 of 4

CERTIFICATION I hereby certify that the foregoing Defendant's Revised Proposed Jury Verdict Form was hand-delivered to counsel for the Plaintiff, John R. Williams, at the Federal Court in Bridgeport, on this 17th day of March, 2004.

_____________________________ Maria C. Rodriguez Mark P. Kindall Assistant Attorneys General Federal Bar Nos. ct08946 & ct13797 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 [email protected] [email protected]