VF-3201. Consequential Damages

We answer the questions submitted to us as follows:

1. Was [name of defendant]'s conduct a substantial factor in causing damages to [name of plaintiff]?

______ Yes  ______ No

If your answer to question 1 is yes, then answer question 2. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

2. Did the damages result from [name of plaintiff]'s requirements and needs?

______ Yes  ______ No

If your answer to question 2 is yes, then answer question 3. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

3. Did [name of defendant] have reason to know of those requirements and needs at the time of the [sale/lease] to [name of plaintiff]?

______ Yes  ______ No

If your answer to question 3 is yes, then answer question 4. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form.

4. Could [name of plaintiff] reasonably have prevented the damages?

______ Yes  ______ No

If your answer to question 4 is no, then answer question 5. If you answered yes, stop here, answer no further questions, and have the presiding juror sign and date this form.

5. What is the amount of [name of plaintiff]'s damages? $

[After it has been signed/After all verdict forms have been signed], deliver this verdict form to the [clerk/bailiff/judge].

Directions for Use

The special verdict forms in this section are intended only as models. They may need to be modified depending on the facts of the case.

This verdict form is based on CACI No. 3243, Consequential Damages.

Normally, this verdict form would be combined with verdict forms containing the underlying cause(s) of action.

If there are multiple causes of action, users may wish to combine the individual forms into one form.

(New September 2003)