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Case 3:15-cv-02281-WHA Document 537 Filed 10/13/21 Page 1 of 3
`Case 3:15-cv-02281-WHA Document 537 Filed 10/13/21 Page 1.of 3
`ORIEN AL
`Ho PEL CIAL COPY
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`TOTAL RECALL TECHNOLOGIES,
`
`Plaintiff,
`
`No. C 15-02281 WHA
`
`Vv.
`
`PALMER LUCKEY,
`
`Defendant.
`
`
`
`SPECIAL JURY VERDICT FORM
`FOR PHASE ONE TRIAL
`
`YOUR ANSWERS MUST BE UNANIMOUS. YOU MUST FOLLOW THE COURT’S FINAL CHARGE
`
`TO THE JURY.
`
`1.
`
`Has defendant provenhis affirmative defense that his consent to the contractual
`
`obligations at issue was obtained by fraud?
`
`Yes
`
`No Va
`
`IF YOUR ANSWERIS “YES,” THEN YOU ARE DONE; GO TO THE END, AND SIGN AND DATE THE
`
`VERDICT FORM. OTHERWISE, GO TO QUESTIONS 2 AND 3.
`
`
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`NorthernDistrictofCalifornia
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`UnitedStatesDistrictCourt
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`Case 3:15-cv-02281-WHA Document 537 Filed 10/13/21 Page 2 of 3
`Case 3:15-cv-02281-WHA Document 537 Filed 10/13/21 Page 2 of 3
`
`2.
`
`Hasplaintiff TRT proven that Luckey breached his contractual obligation to TRT
`
`and that this breach was a substantial and foreseeable factor in causing TRT’s harm?
`
`Yes
`
`No
`
`SY
`
`If you answered “yes,” then state your reason(s) for yourfinding that Luckey breached.
`
`
`
`
`
`3.
`
`With respectto plaintiff's claim of constructive fraud, has plaintiff proven that
`
`Luckey and TRT were in a confidential relationship (within the meaningofthe final charge to ~
`
`the jury)?
`
`Yes
`
`No VA
`
`IF YOUR ANSWERIS “YES,” THEN GO TO THE NEXT QUESTION. OTHERWISE, GO TO THE END
`
`AND SIGN AND DATE THE VERDICT FORM.
`
`
`
`NorthernDistrictofCalifornia
`
`“aoNNDNUOFS
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`\O
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`UnitedStatesDistrictCourt
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`Case 3:15-cv-02281-WHA Document 537 Filed 10/13/21 Page 3 of 3
`Case 3:15-cv-02281-WHA Document:537 Filed 10/13/21 Page 3 of 3
`
`4.
`
`Hasplaintiff TRT proven that Luckey committed constructive fraud?
`
`Yes
`
`_v
`
`Dated: October
`
`! >, 2021,
`

`
`JURY FOREPERSON
`Anon Vorloc.
`
`
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`NorthernDistrictofCalifornia
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`UnitedStatesDistrictCourt
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