United States District Court

For the Northern District of California

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

FREDERICK JACKSON, ASHLEY NICOLE

JACKSON, a minor, BRIANA FREDRANIQUE

ANNETTE JACKSON, a minor, and SHAWNA

YVETTE MARTIN, 

Plaintiffs,

 v.

CITY OF PITTSBURG, AARON L. BAKER,

individually and in his official capacity as Chief of

Police of the City of Pittsburg Police Department,

G. LOMBARDI, individually and as an officer of the

City of Pittsburg Police Department (Badge # 275),

C. SMITH, individually and as an officer of the

City of Pittsburg Police Department (Badge # 285),

P. DUMPA, individually and as an officer of the

City of Pittsburg Police Department (Badge # 291),

WILLIAM BLAKE HATCHER, individually and as

an officer of the City of Pittsburg Police Department

(Badge # 274), and DOES 1–100, inclusive,

Defendants. /

No. C 09-01016 WHA

PROPOSED VERDICT FORM

Case 3:09-cv-01016-WHA Document 192 Filed 07/21/10 Page 1 of 4
United States District Court

For the Northern District of California

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YOUR ANSWERS MUST BE UNANIMOUS.

1. Frederick Jackson

A. Has plaintiff Frederick Jackson proven that any of the following officers

used excessive force against him on March 30, 2008, in violation of the

Fourth Amendment?

Yes No

Officer Lombardi ___________ ____________

Officer Smith ___________ ____________

Officer Dumpa ___________ ____________

B. If so, state the amount of any damages proven:_________________

2. Ashley Jackson

A. Has plaintiff Ashley Jackson proven that Officer Lombardi used

excessive force against her on March 30, 2008, in violation of the Fourth

Amendment?

Yes No

___________ ____________

B. If so, state the amount of any damages proven:_________________

3. Shawna Martin

A. Has plaintiff Shawna Martin proven that Officer Spires used excessive

force against her on March 30, 2008, in violation of the Fourth

Amendment?

Yes No

___________ ____________

Case 3:09-cv-01016-WHA Document 192 Filed 07/21/10 Page 2 of 4
United States District Court

For the Northern District of California

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3

B. If so, state the amount of any damages proven?________________

4. Briana Jackson

A. Has plaintiff Briana Jackson proven her claim of negligent infliction of

emotional distress as to any of the following defendants?

Yes No

Officer Lombardi ___________ ____________

Officer Smith ___________ ____________

Officer Dumpa ___________ ____________

B. If so, state the amount of any damages proven:_________________

5. If you have answered yes to any of Questions 1–3, state whether plaintiffs have

proven by clear and convincing evidence that punitive damages should be

awarded against any officer you find violated any Fourth Amendment rights:

Yes No

Officer Lombardi ___________ ____________

Officer Smith ___________ ____________

Officer Dumpa ___________ ____________

Officer Spires ___________ ____________

If you answer “yes” as to Question 5, then there will be a short supplemental

proceeding immediately after your verdict. The purpose of the short

supplemental proceeding would be to allow you to fix the amount.

Case 3:09-cv-01016-WHA Document 192 Filed 07/21/10 Page 3 of 4
United States District Court

For the Northern District of California

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CONCLUSION

ONCE YOU HAVE FINISHED ANSWERING THE NECESSARY QUESTIONS UNANIMOUSLY,

PLEASE HAVE THE FOREPERSON SIGN AND DATE THIS FORM. THEN CONTACT THE DEPUTY OR

MARSHAL TO INFORM HIM OR HER THAT YOU HAVE COMPLETED YOUR DELIBERATIONS.

Dated: July ____, 2010. 

Foreperson

Case 3:09-cv-01016-WHA Document 192 Filed 07/21/10 Page 4 of 4