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WPI 105.21 Special Verdict Form—Traditional Injury or Loss of Chance of [Survival] [Better Outc...

6 WAPRAC WPI 105.21Washington Practice Series TMWashington Pattern Jury Instructions--Civil

6 Wash. Prac., Wash. Pattern Jury Instr. Civ. WPI 105.21 (7th ed.)
Washington Practice Series TM
Washington Pattern Jury Instructions--Civil
April 2022 Update
Washington State Supreme Court Committee on Jury Instructions
Part IX. Particularized Standards of Conduct
Chapter 105. Health Care
WPI 105.21 Special Verdict Form—Traditional Injury or Loss of Chance of [Survival] [Better Outcome]
IN THE [DISTRICT] [SUPERIOR] COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF
,
Plaintiff,
NO.
vs.SPECIAL
,VERDICT FORM
Defendants.
We, the jury, answer the questions submitted by the court as follows:
QUESTION 1: Was(name of defendant)negligent?
ANSWER: (Write “yes” or “no”)
If you answered “no” to Question 1, do not answer any other questions; sign this verdict form and notify the bailiff. If you answered “yes” to Question 1, proceed to Question 2.
QUESTION 2: Was(name of defendant)'s negligence a proximate cause of the [death] [injury] of [(name of decedent)'s] [(name of plaintiff)'s]?
ANSWER: (Write “yes” or “no”)
If you answered “no” to Question 2, proceed to Question 3. If you answered “yes” to Question 2, do not answer Question 3 or 4; proceed to Question 5.
QUESTION 3: Was(name of defendant)'s negligence a proximate cause of a reduction in [(name of decedent)'s] [(name of plaintiff)'s] chance to [survive the condition which caused [his] [her] death] [have a better outcome]?
ANSWER: (Write “yes” or “no”)
If you answered “no” to Question 3, do not answer any other questions; sign this verdict form and notify the bailiff. If you answered “yes” to Question 3, proceed to Question 4.
QUESTION 4: What do you find to be the percentage reduction in [(name of decedent)'s] [(name of plaintiff)'s] chance to [survive] [have a better outcome] proximately caused by the negligence of(name of defendant)?
ANSWER: % (cannot exceed 50%)
Proceed to Question 5.
QUESTION 5: What do you find to be the [(name of decedent)'s] [(name of plaintiff)'s] total amount of damages?
ANSWER: $
Sign this verdict form and notify the bailiff.
DATE:
Presiding Juror
[Current as of September 2018.]
End of Document