Punitive Damages Verdict V Wyeth Upjohn

Case 4:04-cv-01169-WRW

Document 616

Filed 03/06/2008

Page 1 of 1

VERDICT FORM

1.

Do you find that Ms. Scroggin has proven by clear and convincing evidence that Wyeth knew, or should have known, in light of the surrounding circumstances, that its failure to warn would naturally and probably result in breast cancer and that Wyeth continued such conduct (i) with malice or (ii) in reckless disregard of the consequences from which malice may be inferred and, therefore, that Wyeth should be required to pay her punitive damages?

'£ 2.

___ NO

YES

If you answered "yes" to Question Number 1, state the amount of punitive damages, if any, Wyeth should be required to pay Ms. Scroggin:

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Do you find that Ms. Scroggin has proven by clear and convincing evidence that Upjohn knew, or should have known, in light ofthe surrounding circumstances, that its failure to warn would naturally and probably result in breast cancer and that Upjohn continued such conduct (i) with malice or (ii) in reckless disregard of the consequences from which malice may be inferred and, therefore, that Upjohn should be required to pay her punitive damages?

4.

~YES

___ NO

If you answered "yes" to Question Number 3, state the amount of punitive damages, if any, Upjohn should be required to pay Ms. Scroggin:

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