SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
|GALE K. GOTTLIEB, MICHAEL K. Case No. CIVS01501
\GOTTLIEB, and TAMAR GOTTLIEB
IMCLACHLAN, individually and as
[Suecessors-in-Interest fo the ESTATE OF pr} SPECIAL VERDICT
|KENNETH I. GOTTLIEB, Deceased,
Plaintiffs,
vs.
|FARIDE KHALAR,
Defendant.
We, the jury, answer the questions submitted to us as follows:
1. Was Faride Khalaf negligent?
Vv Yes No
Answer question 2.
2. Did Faride Khalaf make a false representation of an important fact to Dr. Kenneth
Gottlieb?
v yes ___No
If your answer to either question 1 or 2 is yes, then answer question 3. If you answered
no to both questions 1 and 2, then stop here, answer no further questions, and have the
presiding juror sign and date this form,
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SPECIAL VERDICTem am
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Was Faride Khalaf’s negligence, or his false representation to Dr. Kenneth Gottlieb, or
both, a substantial factor in causing harm to Dr. Gottlieb?
yes No
If your answer to question 3 is yes, then answer question 4. If you answered no to
question 3, then stop here, answer no further questions, and have the presiding juror
sign and date this form.
What are the plaintiffs’ damages?
a. Past economic loss:
Lost earnings: 8 00
Total Past Economic Damages: $ 1,40 000
+b, Future economic loss:
Lost earnings: {400,000
Total Future Economic Damages: $_{, {00,000
. Past noneconomic losses:
i, Gale Gottlieb’s past noneconomic loss,
including the loss of Dr. Kenneth Gottlied’s love,
‘companionship, comfort, care, assistance,
protection, affection, society, and moral support,
from August 5, 2009 to the present:
$ 5,000, 000 _
ii, Michael Gottlicb’s past noneconomic loss,
including the loss of Dr. Kenneth Gottlieb’s love,
comfort, care, assistance, protection, affection,
society, and moral support from August 5, 2009
to the present:
$ 1,000, 000
iii, Tamar Gottlieb McLachlan’s past
noneconomic loss, including the loss of Dr.
Kenneth Gottlieb’s love, comfort, care, assistance,
protection, affection, society, and moral support
from August 5, 2009 to the present: 5 |,000,000
Total Past Noneconomic Damags
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‘SPECIAL VERDICTaoe
d, Future noneconomic loss:
i. Gale Gottlieb’s future noneconomic loss,
including the loss of Dr. Kenneth Gottlicb’s love,
companionship, comfort, care, assistance,
protection, affection, society, and moral support, ar
from today forward:
Y $2,500,000
ii, Michael Gottlieb’s future noneconomic loss,
including the loss of Dr. Kenneth Gottlieb’s love,
comfort, care, assistance, protection, affection,
society, and moral support from today forward:
» eS ¥ gs 500,000
iii, Tamar Gottlieb McLachlan’s future
noneconomic loss, including the loss of Dr.
Kenneth Gottlieb’s love, comfort, care, assistance,
protection, affection, society, and moral support
from today forward:
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00000
600 O00
Total Future Noneconomic Damages: $ 8 900,000
TOTAL: $ 13 (0 000
7 & Ab, 2015 signs
t if
After the verdict form has been dated and signed, notify the clerk or bailiff that you are ready to
present your verdict
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‘SPECIAL VERDICT