COURT'S PROPOSED SPECIAL VERDICT FORM

JEFFREY S. WHITE, District Judge.

The following constitutes the Court's proposed verdict form. The parties may file any objections to this form by July 25, 2016 and the Court shall address the objections at the charging confefrence scheduled for July 28, 2016. If the trial progresses more quickly than anticipated, the Court will advise the parties of any modification to this schedule in open court.

IT IS SO ORDERED.

Please respond to the following questions by placing an "X" next to your answer. All of your answers must be unanimous.

1. Has plaintiff, Edin Castellanos, proven by a preponderance of the evidence that defendant, Jeremy Maya, used excessive force against him in violation of the Fourth Amendment?

If you answered yes to this question, please proceed to question 2. If you answered no to this question, please skip questions 2 and 3 and proceed to question 4.

2. Has plaintiff, Edin Castellanos, proven by a preponderance of the evidence, that defendant, Jeremy Maya's use of excessive force proximately caused him damages?

If you answered yes to question 2, please proceed to question 3. If you answered no, you must award plaintiff nominal damages up to one dollar. Please state the amount of nominal damages you award plaintiff, and then proceed to question 4.

3. If you answered yes to question 2, please state the amount of damages you find plaintiff, Edin Castellanos, has proved by a preponderance of the evidence.

4. Has plaintiff, Edin Castellanos, proven that defendant, Jeremy Maya, violated his right to freedom of speech in violation of the First Amendment?

If you answered yes to question 4, you must award plaintiff nominal damages up to one dollar. Please state the amount of nominal damages you award to plaintiff, and then proceed to question 5. If you answered no this question, please proceed directly to question 5.

5. Has plaintiff, Edin Castellanos, proven by a preponderance of the evidence that defendant, Jeremy Maya, deliberately fabricated evidence in his arrest report of the incident and the arrest report was used to criminally charge plaintiff with willfully resisting, delaying or obstructing a police officer?

If you answered yes to question 5, you must award plaintiff nominal damages up to one dollar. Please state the amount of nominal damages you award to plaintiff, and then proceed to question 6. If you answered no this question, please proceed directly to question 6.

6. Please answer this question only if you answered "Yes" to questions 1, 4 or 5. If you answered no to all of those questions, please skip this question and have the presiding juror sign and date this special verdict form.

Has plaintiff, Edin Castellanos, proven by a preponderance of the evidence that defendant, Jeremy Maya, acted with malice, oppression or reckless disregard of plaintiff's rights?

If you answered yes to this question, please have the presiding juror sign and date this form.