Wis JI-Civil 3294

Question 1: Did (plaintiff) ingest white lead carbonate?

Answer: ____________

Yes or No

If your answer to Question 1 is "no," then do not answer any other question. If you answer

Question 1 "yes," then answer Question 2.

Question 2: Was white lead carbonate a cause of (plaintiff)'s injuries?

Answer: ____________

Yes or No

If the answer to Question 2 is "no," do not answer any other question.

Question 3: Answering separately for each defendant listed below, did that

defendant produce or market the type of white lead carbonate ingested by (plaintiff)?

Defendant (A): Yes ________ No ________

Defendant (B): Yes ________ No ________

Defendant (C): Yes ________ No ________

Defendant (D): Yes ________ No ________

Considering only those defendants for whom you answered "yes" to Question 3, answer

this question:

Question 4: Answering separately for each defendant listed below, did the

defendant prove that it did not produce or market the white lead carbonate ingested by

(plaintiff)?

Defendant (A): Yes ________ No ________

Defendant (B): Yes ________ No ________

Defendant (C): Yes ________ No ________

Defendant (D): Yes ________ No ________

Considering only those defendants for whom you answered "no" in Question 4, answer

this question:

Question 5: Answering separately for each defendant, was the defendant

negligent in producing or marketing the white lead carbonate?

Defendant (A): Yes ________ No ________

Defendant (B): Yes ________ No ________

Defendant (C): Yes ________ No ________

Defendant (D): Yes ________ No ________

Question 6: Was (plaintiff) negligent with respect to (his) (her) own safety?

Answer: ____________

Yes or No

If you answered Question 6 "yes," then answer Question 7. If your answer is "no," then

skip to Question 9.

Question 7: Was the negligence of (plaintiff) a cause of (his) (her) injuries?

Answer: ____________

Yes or No

If you answered Question 7 "yes," then answer Question 8. If you answered Question 7

"no," then go to Question 9.

Question 8: Assuming the total negligence that caused the injury to (plaintiff) to

be 100%, what percentage of the total negligence do you attribute to:

(a) All defendants for whom you

answered Question 5 "yes" __________%

(b) (Plaintiff)? __________%

TOTAL 100 %

Before you answer Question 9, draw a line through those producers or marketers of white

lead carbonate to whom you did not answer "yes" in Question 5. As to the rest, answer

this question:

Question 9: Regardless of your answer to 8(a) above, assuming the total

negligence of the remaining producers or marketers to be 100%, what percentage of

negligence, if any, do you attribute to:

Defendant (A): __________%

Defendant (B): __________%

Defendant (C): __________%

Defendant (D): __________%

TOTAL 100 %