Case Document 367 Filed 10/20/16 Page 1 of 5
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IN THE UNITED STATES DISTRICT COURT 0 0
FOR THE SOUTHERN DISTRICT OF MISSISSIPPI CT 0 2915

 

 

 

 

 

 

 

 

SOUTHERN DIVISION ARTHUR JOHNSTON
3* . DEPUTY

WANDA WILLIAMS, Individually and 
as Conservator for John Robert 

Williams, Jr., Incapacitated PLAINTIFF



V. Civil No. CG



MANITOWOC CRANES, LLC DEFENDANT

SPECIAL VERDICT FORM

PART 1:

Question Number One:

On Plaintiff Wanda Williams? claim brought on behalf of Mr. John Robert
Williams, Jr., against Defendant Manitowoc Cranes, LLC, that the Model 16000
crane failed to contain adequate warnings or instructions as to the danger of falling
counterweights, we the jury ?nd by a preponderance of the evidence in favor of:
(Please choose only one.)

Plaintiff Wanda Williams
Defendant Manitowoc Cranes, LLC

Please proceed to Question Number Two.

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Case Document 367 Filed 10/20/16 Page 2 of 5

Question Number Two:

On Plaintiff Wanda Williams? claim brought on behalf of Mr. John Robert
Williams, Jr., against Defendant Manitowoc Cranes, LLC, that the Model 16000
crane failed to contain adequate warnings or instructions as to the danger of
tandem lifts, we the jury ?nd by a preponderance of the evidence in favor of:
(Please choose only one.)

Plaintiff Wanda Williams

Defendant Manitowoc Cranes, LLC

If you found in favor of Plaintiff Wanda Williams in either Question Numbers One or
Two, please proceed to Question Number Three. If you found in favor of Defendant
Manitowoc Cranes, LLC, on both Question Numbers One and Two, you should not
proceed further in Part I, but should proceed to Part II of the Special Verdict Form.

Question Number Three:

What damages, if any, do you ?nd by a preponderance of the evidence would
be reasonable compensation for the injuries actually sustained, if any, by Mr. John
Robert Williams, as a result of the June 25, 2014, tip-over of the Manitowoc
Model 16000 crane bearing Serial No. 1132? (Do not reduce these amounts for any
percentage of fault attributable to other parties since the Court will address this.)

Actual Economic Damages 7, 

Noneconomic Damages m?


Total 

Please proceed to Question Number Four.

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Case Document 367 Filed 10/20/16 Page 3 of 5

Question Number Four:

Has Plaintiff Wanda Williams proved by a preponderance of the evidence her
loss of consortium claim against Defendant Manitowoc Cranes, 

Yes 

No

If your Answer to Question Number Four is ?Yes, proceed to Question Number Five.
If your Answer to Question Number Four is ?No, you should proceed to Question
Number Six.

Question Number Five:

What damages, if any, do you ?nd by a preponderance of the evidence were
incurred by Plaintiff Wanda Williams resulting from the injury to her
husband, Mr. John Robert Williams, Jr.? (Do not reduce these amounts for any
percentage of fault attributable to other parties since the Court Will address this.)

$507; an?

Please proceed to Question Number Six.

Question Number Six:

Do you ?nd by a preponderance of the evidence that the negligence, if any, of
Mr. John Robert Williams, or the negligence, if any, of VT Halter Marine, Inc.,
proximately caused or contributed to cause Mr. John Robert Williams, r.?s injuries?

Yes

No

If your Answer to Question Number Six is ?Yes, please proceed to Question Number
Seven. If your Answer to Question Number Six is ?No, you should not proceed
further in Part I, but should proceed to Part II of the Special Verdict Form.

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Case Document 367 Filed 10/20/16 Page 4 of 5

Question Number Seven:

What percentage of fault, if any, do you ?nd by a preponderance of the
evidence should be attributed to each responsible party? (The total must equal
100%. If a party?s conduct was not negligent or did not proximately cause Mr.
,Williams? injury, please assess 0% fault as to that party.)

Manitowoc Cranes, LLC  

John Robert Williams, Jr. /0 
VT Halter Marine, Inc. 6 '0 
Total 100%

Please proceed to Part II.

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PART II:
FINALIZATION OF THE VERDICT FORM

Please date and sign below:

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Foreperson Juror

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