`Case 3:17-cv-06748-WHO Document 291 Filed 10/04/21 Page 1 of 4
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`UNITED STATESDISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`OWENDIAZ,
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`Case No. 3:17-cv-06748-WHO
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`VERDICT FORM
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`Plaintiff,
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`Vv.
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`TESLA,INC., et al.,
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`Defendants.
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`We,the Jury, find as follows:
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`1. Was Owen Diaz subjected to a racially hostile work environment by Tesla, Inc.?
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`(Instruction Nos. 26-33).
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`J YES
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`NO
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`Ifyou answered “yes,” proceed to the next question. Ifyou answered “no,” proceed to
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`question 4.
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`2. Was Tesla, Inc., a joint employer of Owen Diaz? (Instruction No. 24)
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`J YES
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`NO
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`Ifyou answered “yes,” proceed to the next question. Ifyou answered “no,” answer
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`question 4.
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`UnitedStatesDistrictCourt
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`—_
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`&.WHWN
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`Case 3:17-cv-06748-WHO Document 291 Filed 10/04/21 Page 2 of 4
`Case 3:17-cv-06748-WHO Document 291 Filed 10/04/21 Page 2 of 4
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`3. Did Owen Diaz proveall of the elementsof:
`A. Hostile work environment caused by a
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`J YES
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`supervisor (Instruction No. 29)
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`B. Hostile work environment caused by a
`non-immediate supervisor or co-worker
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`ft
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`YES
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`NO
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`NO
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`(Instruction No. 32)
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`Answer the next question.
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`. Did Owen Diaz proveall of the elementsofliability based on civil rights violation in a
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`contractual relationship? (Instruction No. 37)
`v YES
`NO
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`Ifyou answered “no”to questions 3A, 3B, and 4, skip question 5 andproceed to question
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`6.
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`. Did Tesla,Inc., fail to take all reasonable steps necessary to prevent Owen Diaz from
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`being subject to racial harassment? (Instruction No. 34)
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`J YES
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`NO
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`Answerthe next question.
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`. Did Tesla, Inc.’s negligent supervision or continued employment of Ramon Martinez
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`cause harm to Owen Diaz? (Instruction No. 35)
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`J YES
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`NO
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`Ifyou answered “yes” to either question 3, 4, 5, or 6 answer the next question. Ifyou
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`answered “no”to all ofthose questions, thejuryforeperson should sign, date, and return thisjury
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`questionnaire.
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`UnitedStatesDistrictCourt
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`Case 3:17-cv-06748-WHO Document 291 Filed 10/04/21 Page 3 of 4
`Case 3:17-cv-06748-WHO Document 291 Filed 10/04/21 Page 3 of 4
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`DAMAGES
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`(Instruction Nos. 38-41)
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`7. What past non-economic damages did Owen Diaz sustain as a result of Tesla, Inc.’s
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`unlawful conduct?
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`$_4 500,000
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`Go to the next question.
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`8. What future non-economic damages is Owen Diaz likely to sustain as a result of Tesla,
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`Inc.’s unlawful conduct?
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`$_ 2,400 OOO
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`PUNITIVE DAMAGESFOR CIVIL RIGHTS CLAIMS
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`(Instruction No. 40)
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`9. You may only award punitive damagesfor the reasons discussed in Instruction No. 40, that
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`is, if you find that the defendant’s conduct that harmed the plaintiff was malicious,
`oppressive orin reckless disregard ofthe plaintiff's rights. Do you find by a
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`preponderanceof the evidence that Owen Diazis entitled to punitive damages against
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`Tesla Inc. for either creating a hostile work environment based on race (question 3A or
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`3B), violating civil rights in a contractual relationship (question 4), and/orfailing to
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`prevent harassmentbased on race in the workplace (question 5)?
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`J YES
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`NO
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`Ifyou answered “yes” to question 9, answer the next question. Ifyou answered “no,” sign
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`date and return thisjuror questionnaire.
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`OoCOJDDAnAFSWDHO
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`NorthernDistrictofCalifornia
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`Case 3:17-cv-06748-WHO Document 291 Filed 10/04/21 Page 4 of 4
`Case 3:17-cv-06748-WHO Document 291 Filed 10/04/21 Page 4 of 4
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`10. What amount of punitive damages do you award to Owen Diaz?
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`$
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`| 30,000,000
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`When you have reachedyourverdict, thejuryforeperson should sign and date thisform
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`and contact the courtroom deputy, Ms. Davis.
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`DATED: October 4, 202\
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`JURY FOREPERSON
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`—oOfoNYDBWwWFPWLO
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