EXHIBIT B 

Case 3:17-cv-00600-LB Document 120-2 Filed 09/06/19 Page 1 of 4
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 Case No. 3:17-cv-00600-LB

DEFENDANTS’ PROPOSED VERDICT FORM 

335865.1 

DALE L. ALLEN, JR., State Bar No. 145279 

dallen@aghwlaw.com 

PHILIP J. DOWNS, JR., State Bar No. 302939 

pdowns@aghwlaw.com 

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 

180 Montgomery Street, Suite 1200 

San Francisco, California 94104 

Telephone: (415) 697-2000 

Facsimile: (415) 813-2045 

Attorneys for Defendants 

COUNTY OF NAPA, COUNTY OF NAPA SHERIFF’S 

DEPARTMENT, DEPUTY TIMOTHY REID 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

RENEE LEPAGE, an individual, 

Plaintiff, 

vs. 

COUNTY OF NAPA, COUNTY OF NAPA 

SHERIFF’S DEPARTMENT AND DOE 

DEPUTIES 1-100, 

Defendants. 

 Case No. 3:17-cv-00600-LB 

DEFENDANT TIM REID PROPOSED 

VERDICT FORM

 

 

Case 3:17-cv-00600-LB Document 120-2 Filed 09/06/19 Page 2 of 4
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 -2- Case No. 3:17-cv-00600-LB

DEFENDANTS’ PROPOSED VERDICT FORM 

335865.1 

Claim of Excessive Force (42 U.S.C. § 1983 and Fourth Amendment) 

1. Did defendant Timothy Reid use excessive force against the plaintiff Renee LePage in 

violation of the Fourth Amendment to the U.S. Constitution? 

Yes: ____________ No: ____________ 

Proceed to Question 2. 

Claim of Violation of Civil Rights (Cal. Civ. Code § 52.1, known as the Bane Act) 

2. Did defendant Reid interfere with or attempt to interfere with the plaintiff’s enjoyment of 

her right to be free from unreasonable seizure in violation of the Bane Act? 

Yes: ____________ No: ____________ 

Proceed to Question 3. 

Battery Claim 

3. Did defendant Reid commit a battery against the plaintiff? 

Yes: ____________ No: ____________ 

Proceed to Question 4. 

Claim of Negligence 

4. Was defendant Reid negligent? 

Yes: ____________ No: ____________ 

Proceed to Question 5. 

Damages 

5. Did you answer yes to at least one of the following questions: 1, 2, 3, or 4? 

Yes: ____________ No: ____________ 

If your answer is No, you have reached a verdict, and you must stop here, and have the 

presiding juror sign and date this form. If your answer is Yes, then proceed to Question 6. 

6. Did you find by a preponderance of the evidence that the actions of Deputy Reid was the 

substantial cause of injury to Ms. LePage? 

Yes: ____________ No: ____________ 

7. If you answered Yes to question 6 what amount of damages do you award to compensate 

the plaintiff? 

$ _____________________ 

Proceed to Question 8. 

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 -3- Case No. 3:17-cv-00600-LB

DEFENDANTS’ PROPOSED VERDICT FORM 

335865.1 

8. Answer question #8 if you answered “Yes” to Question number 1, but answered zero “$0” 

or no damages to question number 7. You must award Ms. LePage an amount of nominial 

damages not to exceed $1.00. What amount of nominal damages do you award? 

$ _____________________ 

9. If you answered Yes to question 1 or 2, was Reid’s conduct malicious, oppressive or 

committed in reckless disregard of the plaintiff’s rights? 

Yes: ____________ No: ____________ 

If your answer is No, you have reached a verdict, and you must stop here, and have the 

presiding juror sign and date this form. If your answer is Yes, then proceed to Question 8. 

10. If you answered Yes to question 7, what amount of punitive damages do you award to the 

plaintiff? 

$ _____________________ 

Please have the presiding juror sign and date the form. 

Signed: _______________________________________ (Presiding Juror) 

Dated: ________________________________________ 

Case 3:17-cv-00600-LB Document 120-2 Filed 09/06/19 Page 4 of 4