VF-2506B. Hostile Work Environment Harassment--Conduct Directed at Others--Employer or Entity Defendant (Gov. Code, § 12940(j)) Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 We answer the questions submitted to us as follows: 1. Was [name of plaintiff] [an employee of/a person providing services under a contract with] [name of defendant]? ____ 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 [name of plaintiff] personally witness harassing conduct that took place in [his/her] immediate work environment? ____ 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. Was the harassment severe or pervasive? ____ 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. Would a reasonable [describe member of protected group, e.g., woman] in [name of plaintiff]'s circumstances have considered the work VF-2506B. Hostile Work Environment Harassment--Conduct Directed at Others--Employer or Entity Defendant (Gov. Code, § 12940(j)) Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 environment to be hostile or abusive? ____ Yes ____ No If your answer to question 4 is yes, then answer question 5. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form. 5. Did [name of plaintiff] consider the work environment to be hostile or abusive toward [e.g., women]? ____ Yes ____ No If your answer to question 5 is yes, then answer question 6. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form. 6. Did [name of defendant] [or [his/her/its] supervisors or agents] know or should [he/she/it/they] have known of the harassing conduct? ____ Yes ____ No If your answer to question 6 is yes, then answer question 7. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form. 7. Did [name of defendant] [or [his/her/its] supervisors or agents] fail to take immediate and appropriate corrective action? VF-2506B. Hostile Work Environment Harassment--Conduct Directed at Others--Employer or Entity Defendant (Gov. Code, § 12940(j)) Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 ____ Yes ____ No If your answer to question 7 is yes, then answer question 8. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form. 8. Was the harassing conduct a substantial factor in causing harm to [name of plaintiff]? ____ Yes ____ No If your answer to question 8 is yes, then answer question 9. If you answered no, stop here, answer no further questions, and have the presiding juror sign and date this form. 9. What are [name of plaintiff]'s damages? [a. Past economic loss [lost earnings [lost profits [medical expenses [other past economic loss Total Past Economic Damages: $ $ $ $ $ ] ] ] ] ] VF-2506B. Hostile Work Environment Harassment--Conduct Directed at Others--Employer or Entity Defendant (Gov. Code, § 12940(j)) Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 [b. Future economic loss [lost earnings [lost profits [medical expenses [other future economic loss $ $ $ $ ] ] ] ] ] ] ] Total Future Economic Damages: $ [c. Past noneconomic loss, including [physical pain/mental suffering:] $ $ $ [d. Future noneconomic loss, including [physical pain/mental suffering:] TOTAL Signed: Dated: Presiding Juror After [this verdict form has/all verdict forms have] been signed, notify the [clerk/bailiff/court attendant] that you are ready to present your verdict in the courtroom. ____________________________________________________________________________ Derived from former CACI No. VF-2506 December 2007; Revised December 2010, June 2013, December 2016