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| IDJI 151
(Full Court Heading) SPECIAL VERDICT
Single Plaintiff, Single Defendant
Form I. We, the jury, find for the plaintiff (name) and against the defendant (name) and assess plaintiff's damages at $_________ [for compensation and at ($) for punitive or exemplary purposes.]
Form II. We, the jury, find for the defendant (name) and against the plaintiff (name).
Single Plaintiff, Single Defendant, Counterclaim
Form III. On the claim of plaintiff (name) against defendant (name), we, the jury, find for the plaintiff and against the defendant and assess plaintiff's damages at $________. On the claim of defendant against plaintiff, we also find for the plaintiff.
Form IV. On the claim of defendant (name) against plaintiff (name), we, the jury, find for the defendant and against the plaintiff and assess defendant's damages at $_________. On the claim of plaintiff against defendant, we also find for the defendant.
Form V. On the claim of plaintiff (name) against defendant (name), we, the jury, find for the defendant and against the plaintiff. On the claim of defendant against plaintiff, we find against the defendant and for the plaintiff.
Single Plaintiff, Single Defendant Multiple Claims and Counterclaims Form VI.
On the first claim of plaintiff (name) against defendant (name), we, the jury, find for ( ). [Insert "plaintiff" or "defendant"]. [If the jury finds for the plaintiff on this claim, complete also the following: We assess plaintiff's damages at $________.] [If the jury finds for the defendant on this claim, complete also the following: On the defendant's (first) counter-claim to plaintiff's first claim, we find for ________ [insert "plaintiff" or "defendant"]. [If the jury finds for the defendant on this counterclaim, complete also the following: We assess defendant's damages at $________.] [NOTE: This form can be expanded to cover as many claims and counterclaims as may be submitted to the jury.]
Multiple Plaintiffs, Single Defendant
Form VII. On the claim of the plaintiffs (name), (name) and (name) against defendant (name), we, the jury, find against the defendant and for the following plaintiff or plaintiffs, assessing their damages as indicated: For Plaintiffs Damages ________________________ $_____________________ ________________________ $_____________________ ________________________ $_____________________ And we find for the defendant and against the following plaintiff or plaintiffs: (Insert names of plaintiffs, if any, against whom verdicts are being found.) ______________________________ ______________________________ ______________________________ [NOTE: For counterclaims by a single defendant against multiple plaintiffs, Form VIII can be adapted and used in the manner indicated in Form IV.]
Single Plaintiff, Multiple Defendants
Form VIII. On the single claim of the plaintiff (name) against defendants (name), (name), and (name), we, the jury, find for the plaintiff against the following defendant or defendants: (Insert names of defendant or defendants, if any, against whom verdicts are being found.) ______________________________ ______________________________ ______________________________ If the jury finds for plaintiff and against any one or more defendants, complete also the following: We assess plaintiff's damages at $___________. [NOTE: For counterclaims by multiple defendants against a single plaintiff, Form VII can be adapted and used in the manner indicated in Form VI.]
Multiple Plaintiffs, Multiple Defendants Multiple Claims, Multiple Counterclaims
Form IX. On the claim of plaintiffs (name), (name), and (name), against defendants (name), (name), and (name), we, the jury, find for and against the parties in the following manner and, when we find for a plaintiff, we assess that plaintiff's damages at the amount indicated: (1) As to plaintiff (name), we find for this plaintiff and against defendant or defendants, if any, against whom verdicts are being found for plaintiff (name) and assess plaintiff's damages at $__________; and we find against this plaintiff and for all other defendants, if any. (2) Etc., etc.
Multiple Plaintiffs, Multiple Defendants Multiple Claims, Multiple Counterclaims
Form X. On the first claim of plaintiffs (name), (name), and (name), against defendants (name), (name), and (name), we, the jury, find for and against these parties in the following manner and, when we find for a plaintiff on that plaintiff's claim, we assess that plaintiff's damages at the amount indicated: (1) As to plaintiff (name), we find for this plaintiff on this first claim and against defendant or defendants (Insert names of defendant or defendants, if any, against whom verdicts are being found for plaintiff (name) on this claim.) (name) and assess plaintiff's damages at $__________; and we find against this plaintiff and for all other defendants, if any, on this claim. (2) Etc., etc. (3) . . . [NOTE: Likewise for other claims by plaintiffs.] Instructions: If the jury has up to this point found any verdict in favor of any defendant against any plaintiff, the jury may then find a verdict or verdicts on the counterclaim or counterclaims of any such defendant against any plaintiff or plaintiffs, consistently with the foregoing verdicts. For this purpose, the following is made available:On the first counterclaim of defendants (name), (name), and (name) [against the first claim of plaintiffs], we, the jury, find for and against these parties in the following manner and, when we find for a defendant on that defendant’s counterclaim, we assess that defendant’s damages at the amount indicated: (21) As to defendant (name), we find for the defendant on this first counterclaim and against plaintiff or plaintiffs (insert names of plaintiff or plaintiffs, if any, [against whom there was found a verdict on the plaintiffs’ first claim] and against whom verdicts are being found for Defendant (name) on this counterclaim) and assess defendant’s damages at $___________; and we find against this defendant and for all other plaintiffs, if any, on this counterclaim. (22) Etc., etc. (23) . . .
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