Parrish et al v. National Football League Players Incorporated

Filing 546

Jury Instructions for Closing Arguments (Attachments: # 1 Supplement Special Verdict Form)(whalc1, COURT STAFF) (Filed on 11/6/2008)

1 2 3 4 5 6 7 8 9 10 HERBERT ANTHONY ADDERLEY, on behalf of himself and all others similarly situated, Plaintiffs, v. NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, a Virginia corporation, and NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a PLAYERS INC., a Virginia corporation, Defendants. / No. C 07-00943 WHA IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

United States District Court

11
For the Northern District of California

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. 1.

SPECIAL VERDICT FORM

YOUR ANSWERS MUST BE UNANIMOUS On behalf of the class, has plaintiff proven by a preponderance of the evidence a

class-wide breach of any term of the RPGLA? Yes _______ No _______

If the answer to Question No. 1 is "Yes," then state the amount of damages to

class members, if any, plaintiff has proven by reason of any such breach.

$____________________

1 2 3 4 5 6 7 8 9 10

3.

On behalf of the class, has plaintiff proven by a preponderance of the evidence

that defendants owed a fiduciary duty to the RPGLA Class in connection with the RPGLA? Yes _______ No _______

4.

If your answer to Question No. 3 is "Yes," then state whether plaintiff has

proven by a preponderance of the evidence any class-wide breach of fiduciary duty by defendants under the RPGLA? Yes _______ No _______

5.

If the answer to Question No. 4 is "Yes," then state the amount of damages to

United States District Court

11
For the Northern District of California

class members, if any, plaintiff has proven by reason of any such breach.

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Dated: November ___, 2008. (If your answer to Question No. 6 is "Yes," then a short supplemental proceeding will take place for you to decide the amount of punitive damages.) 6. If the answers to Questions No. 3 and No. 4 are "Yes," then state whether (Any damages on Question No. 5 should exclude any damages on Question No. 2.) $____________________

plaintiff has proven by clear and convincing evidence that punitive damages should be imposed on defendants. Yes _______ No _______

_____________________________________ FOREPERSON