CJI-Civ. 14:31B

FORM A

District Court County Court Other

County, Colorado

Court Address:

[Insert Information from the original caption here - ex. In Re the

Matter of, etc.]

COURT USE ONLY

Case Number:

Division: Courtroom:

SPECIAL VERDICT FORM A

DO NOT ANSWER THIS SPECIAL VERDICT FORM A IF YOUR FOREPERSON HAS

COMPLETED AND ALL JURORS HAVE SIGNED EITHER SPECIAL VERDICT

FORM B OR SPECIAL VERDICT FORM C.

We, the jury, present our Answers to Questions submitted by the Court, to which

we have all agreed:

1. Do you find that the plaintiff, (name), is entitled to recover damages from the

defendant, (name of first defendant), on (insert applicable pronoun) claim of (insert

appropriate description, e.g., “negligence,” “breach of the warranty of. . . ,” etc.) under

Instruction No. (insert the number assigned in the case to the instruction that sets forth the

basic elements of liability for the claim, as in Instructions 14:1, 14:8, 14:10, 14:13, 14:17,

14:20, or 14:22)? (Yes or No)

ANSWER: _______

(Insert additional separately numbered similar paragraphs so as to include all product

liability claims being made against the first defendant.)

(ANSWER: _______)

2. Do you find that the plaintiff, (name), is entitled to recover damages from the

defendant, (name of second defendant), on (insert applicable pronoun) claim of (insert

appropriate description, e.g., “negligence,” “breach of the warranty of. . . ,” etc.), under

Instruction No. (insert the number assigned in the case to the instruction that sets forth the

basic elements of liability for the claim, as in Instructions 14:1, 14:8, 14:10, 14:13, 14:17,

14:20, or 14:22)? (Yes or No)

ANSWER: _______

(Insert additional separately numbered similar paragraphs so as to include all product

liability claims being made against the second defendant.)

(ANSWER: _______)

We, the jury, having answered (both) (all) of these questions numbered (insert

numbers) “no,” find the issues for (both) (all) the Defendants, (names).

__________________ __________________

__________________ __________________

__________________ __________________

Foreperson

FORM B

District Court County Court Other

County, Colorado

Court Address:

[Insert Information from the original caption here - ex. In Re the

Matter of, etc.]

COURT USE ONLY

Case Number:

Division: Courtroom:

SPECIAL VERDICT FORM B

DO NOT ANSWER THIS SPECIAL VERDICT FORM B IF YOUR FOREPERSON HAS

COMPLETED AND ALL JURORS HAVE SIGNED EITHER SPECIAL VERDICT

FORM A OR SPECIAL VERDICT FORM C.

We, the jury, present our Answers to Questions submitted by the Court, to which

we have all agreed:

1. Do you find that the plaintiff, (name), is entitled to recover damages from the

defendant, (name of first defendant), on (insert applicable pronoun) claim of (insert

appropriate description, e.g., “negligence,” “breach of the warranty of. . . ,” etc.) under

Instruction No. (insert the number assigned in the case to the instruction that sets forth the

basic elements of liability for the claim, as in Instructions 14:1, 14:8, 14:10, 14:13, 14:17,

14:20, or 14:22)? (Yes or No)

ANSWER: _______

(Insert additional separately numbered similar paragraphs so as to include all product

liability claims being made against the first defendant.)

(ANSWER: _______)

2. Do you find that the plaintiff, (name), is entitled to recover damages from the

defendant, (name of second defendant), on (insert applicable pronoun) claim of (insert

appropriate description, e.g., “negligence,” “breach of the warranty of. . . ,” etc.), under

Instruction No. (insert the number assigned in the case to the instruction that sets forth the

basic elements of liability for the claim, as in Instructions 14:1, 14:8, 14:10, 14:13, 14:17,

14:20, or 14:22)? (Yes or No)

ANSWER: _______

(Insert additional separately numbered similar paragraphs so as to include all product

liability claims being made against the second defendant.)

(ANSWER: _______)

3. Do you find that the plaintiff was (negligent) (or) (at fault) in causing (insert

applicable pronoun) own (injuries) (damages) (losses) as set forth in Instruction No. (insert

the number of the instruction assigned in the case to the instruction that sets forth the basic

elements of any form of comparative fault, e.g., as in Instruction 14:28 or 14:29)? (Yes or No)

ANSWER: _______

(Insert, as above in question 3, but in separately numbered questions, any additional

forms of comparative fault.)

(ANSWER: _______)

4. State the total amount of plaintiff’s (injuries) (damages) (losses) under Instruction

No. (insert the number assigned in the case to the instruction that sets forth recoverable

damages) that were caused by the combined (negligence) (or) (fault) of all of the Defendants

from whom you have found that plaintiff is entitled to recover.

ANSWER: $_______

5. Taking as 100 percent the combined (negligence) (or) (fault) that caused the

plaintiff’s (injuries) (damages) (losses), what percentage was caused by the (negligence) (or)

(fault), if any, of:

a. the defendant, (name of first defendant); and

b. the defendant, (name of second defendant).

You must enter the figure of zero, “0,” for any defendant you have found was not

(negligent) (or) (at fault).

ANSWER:

Percentage, if any, charged to defendant, (name of first defendant): _______%

Percentage, if any, charged to defendant, (name of second defendant): _______%

MUST TOTAL: 100% _______%

__________________ __________________

__________________ __________________

__________________ __________________

Foreperson

FORM C

District Court County Court Other

County, Colorado

Court Address:

[Insert Information from the original caption here - ex. In Re the

Matter of, etc.]

COURT USE ONLY

Case Number:

Division: Courtroom:

SPECIAL VERDICT FORM C

DO NOT ANSWER THIS SPECIAL VERDICT FORM C IF YOUR FOREPERSON HAS

COMPLETED AND ALL JURORS HAVE SIGNED EITHER SPECIAL VERDICT

FORM A OR SPECIAL VERDICT FORM B.

We, the jury, present our Answers to Questions submitted by the Court, to which

we have all agreed:

1. Do you find that the plaintiff, (name), is entitled to recover damages from the

defendant, (name of the first defendant), on (insert applicable pronoun) claim of (insert

appropriate description, e.g., “negligence”, “breach of the warranty of. . . ,” etc.) under

Instruction No. (insert the number assigned in the case to the instruction that sets forth the

basic elements of liability for the claim, as in Instructions 14:1, 14:8, 14:10, 14:13, 14:17,

14:20, or 14:22)? (Yes or No)

ANSWER: _______

(Insert additional separately numbered similar paragraphs so as to include all product

liability claims being made against the first defendant.)

(ANSWER: _______)

2. Do you find that the plaintiff, (name), is entitled to recover damages from the

defendant, (name of second defendant), on (insert applicable pronoun) claim of (insert

appropriate description, e.g., “negligence,” “breach of the warranty of. . . ,” etc.) under

Instruction No. (insert the number assigned in the case to the instruction that sets forth the

basic elements of liability for the claim, as in Instructions 14:1, 14:8, 14:10, 14:13, 14:17,

14:20, or 14:22)? (Yes or No)

ANSWER: _______

(Insert additional separately numbered similar paragraphs so as to include all product

liability claims being made against the second defendant.)

(ANSWER: _______)

3. Do you find that the plaintiff was (negligent) (or) (at fault) in causing (insert

applicable pronoun) own (injuries) (damages) (losses) as set forth in Instruction No. (insert

the number assigned in the case to the instruction that sets forth the basic elements of any form

of comparative fault, e.g., as in Instruction 14:28 or 14:29)? (Yes or No)

ANSWER: _______

(Insert, as above in question 3, but in separately numbered questions, any additional

forms of comparative fault.)

(ANSWER: _______)

4. State the total amount of plaintiff’s (injuries) (damages) (losses) under Instruction

No. (insert the number assigned in the case to the instruction that sets forth recoverable

damages) that were caused by the combined (negligence) (or) (fault) of all of the defendants

from whom you have found that plaintiff is entitled to recover and the (negligence) (or)

(fault) of the plaintiff.

ANSWER: $_______

5. Taking as 100 percent the combined (negligence) (or) (fault) that caused the

plaintiff’s (injuries) (damages) (losses), what percentage was caused by the (negligence) (or)

(fault), if any, of:

a. the plaintiff, (name); and

b. the defendant, (name of first defendant); and

c. the defendant, (name of second defendant).

You must enter the figure of zero, “0,” for any defendant you have found was not

(negligent) (or) (at fault).

ANSWER:

Percentage charged to plaintiff, (name): _______%

Percentage, if any, charged to defendant, (name of first defendant): _______%

Percentage, if any, charged to defendant, (name of second defendant): _______%

MUST TOTAL: 100% _______%

__________________ __________________

__________________ __________________

__________________ __________________

Foreperson