Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #: 0 0 '~` ~, FLED CLE~sK. ~~. C!~TFiICT COURT ~IJG I i ~~i CENTRAL D~SrTRICT OF CALIFORNIA UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION HALEY VIDECKIS and LAYANA WHITE, individuals, v. Plaintiffs, PEPPERDINE UNIVERSITY, a corporation doing business in Car fornia, Defendant. CASE NO. :-CV-00-DDP (JCx) VERDICT FORM FOR PLAINTIFF HALEY VIDECKS [Assigned to Hon. Dean D. Pregerson, Courtroom C] VIOLATION OF RIGHT OF PRIVACY. Did Plaintiff Haley Videckis have a reasonable expectation of privacy? If your answer to question is yes, answer question. If your answer to question is no, go to and answer question 0.. Did Defendant Pepperdine University intentionally intrude into Plaintiff Videckis' privacy?. 0- iooz i - Case. :-CV-00-DDP (JCx) '
Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #: 0 0 If your answer to question is yes, answer question. If your answer to question is no, go to and answer question 0.. Did Plaintiff Videckis consent to Defendant Pepperdine's intrusion into her privacy? If your answer to question is no, answer question. If your answer to question is yes, go to and answer question 0.. Was Defendant Pepperdine's intrusion into Plaintiff Videckis' privacy justified? If your answer to question is yes, answer question S. If your answer to question is no, go to and answer question.. If you found Defendant Pepperdine's intrusion into Plaintiff Videckis' privacy was justified, did Plaintiff Videckis prove there was a practical, effective, and less invasive method of achieving Defendant Pepperdine's purpose? If your answer to question S is yes, answer question. If your answer to question S is no, go to and answer question D. /// /// ///. 0- iooz i ' Case. :-CV-00-DDP (JCx) VERDICT FORM HALEY VIDECKIS
Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #:. Would Defendant Pepperdine's intrusion into Plaintiff Videckis' privacy be highly offensive to a reasonable person? If your answer to question is yes, answer question. If your answer to question is no, go to and answer question 0.. Was Plaintiff Videckis harmed by Defendant Pepperdine intruding into ' 0 her privacy? If your answer to question is yes, answey question. If your answer to question is no, go to and answer question 0.. Was Defendant Pepperdine's conduct intruding into her privacy a substantial factor in causing Plaintiff Videckis harm? 0 If your answer to question is yes, answer question. If your answer to question is no, go to and answer question 0.. Did Plaintiff Videckis prove by clear and convincing evidence that Defendant Pepperdine acted with malice, oppression, or fraud in intruding into her privacy? WhetheY your answer to question is yes or no, go to and answer question 0.. 0-00P- Case. :-CV-00-DDP (JCx) 00/'I~
Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #: 0 VIOLATION OF TITLE IX AND EDUCATION CODE X0 0. Did Plaintiff Haley Videckis suffer discrimination and/or harassment based upon her sexual orientation, and/or retaliation for making complaints about discrimination or harassment based upon her sexual orientation? If youy answer to question 0 is yes, answer question. If your answer to question 0 is no, go to and answer question S.. Was the discrimination, harassment, and/or retaliation suffered by Plaintiff Videckis so severe, pervasive, and objectively offensive that it effectively deprived her of the right of equal access to educational benefits and opportunities? If your answer to question is yes, answer question. If your answey to question is no, go to and answer question S.. Did Defendant Pepperdine have actual knowledge of the 0 discrimination, harassment, and/or retaliation suffered by Plaintiff Videckis? If your answer to question is yes, answer question. If your answer to question is no, go to and answer question S. /// /// /// ///. 0-00 00 / Case. :-CV-00-DDP (JCx) NAT FV VTTF(`KTQ
Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #: 0 0. Did Defendant Pepperdine act with deliberate indifference in the face of its knowledge? If your answer to question is yes, answer question. If your answer to question is no, go to and answer question.. Did Plaintiff Videckis prove by clear and convincing evidence that Defendant Pepperdine acted with malice, oppression, or fraud? Whether your answer to question is yes or no, go to and answer question S. UNRUH CIVIL RIGHTS ACT. Did Defendant Pepperdine University deny full and equal access to accommodations, advantages, facilities, privileges, or services to Plaintiff Haley Videckis? ~~. If your answer to question S is yes, answer question. If your answer to question is no, go to and answer question.. Was Defendant Pepperdine's perception of Plaintiff Videckis' sexual orientation a substantial motivating reason for Defendant Pepperdine's conduct?. 0-00pp- Case. :-CV-00-DDP (JCx) 00/~I~
Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #:0 If youy answer to question is yes, answer question. If your answer to question is no, go to and answey question.. Was Plaintiff Videckis harmed? ' If your answer to question is yes, answer question. If your answey to question is no, go to and answer question. 0. Was Defendant Pepperdine's conduct a substantial factor in causing harm to Plaintiff Videckis? Whether your answer to question is yes or no, go to and answer question fl'~ INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS. Was Defendant Pepperdine University's conduct outrageous? 0 If your answer to question is yes, answer question 0. If your answer to question is no, go to and answer question.. 0-00 - Case. :-CV-00-DDP (JCx) 00 / ~ VERDICT FORM HALEY VIDECKIS
Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #: E:~ 0 0 0. Did Defendant Pepperdine intend to cause Plaintiff Videckis emotional distress or act with reckless disregard of the probability Plaintiff Videckis would suffer emotional distress? If your answer to question 0 is yes, answer question. If your answey to question 0 is no, go to and answer question.. Did Plaintiff Videckis suffer severe emotional distress? If your answer to question is yes, answer question. If your answer to question is no, go to and answer question.. Was Defendant Pepperdine's conduct a substantial factor in causing Plaintiff Videckis' severe emotional distress? If your answer to question is yes, answer question. If your answer to question is no, go to and answer question.. Did Plaintiff Videckis prove by clear and convincing evidence that Defendant Pepperdine acted with malice, oppression, or fraud?. Whether your answer to question is yes or no, go to and answer question. 0-00yp- '] Case. :-CV-00-DDP (JCx) 00/~~~
Case :-cv-00-ddp-jc Document Filed 0// Page of Page ID #: 0 0 DAMAGES. If you answered yes to questions,,, or then specify Plaintiff Haley Videckis' damages by inserting numbers in the blank spaces below. If you did not answer yes to any of these questions, do not insert any numbers in the blanks and have the presiding juror sign and date this form and submit it to the Court. a. Past economic loss $ b. Future economic loss $ c. Past noneconomic loss, including physical pain/mental suffering: $ d. Future noneconomic loss, including physical pain/mental suffering: $ TOTAL $ If youy answer to question is yes, then answer question.. If your answer to question was yes, what amount, if any, do you award as a penalty against Pepperdine for its violation of the Unruh Act: Once you have completed the verdict form, have the presiding juror sign and date it and submit it to the Court. DATED: ~~ ~,r ~~ ~-; fi. z ~ t. 0- ioo i ' $ Case. :-CV-00-DDP (JCx)