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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
SZ HUA HUANG, Individually and as Case No, 19CV346663
successor in interest to WEI LUN HUANG,
deceased; TRINITY HUANG, a minor; SPECIAL VERDICT FORM
TRISTAN HUANG, a minor,
Vv.
Plaintiffs,
FILE
THE STATE OF CALIFORNIA,
MAY 2 8 2024
Tk of the Court
10
Defendants.
BY. Lex
secomara Santa Cara
————____DePuty
Il
12 We answer the questions submitted to us as follows:
13 DANGEROUS CONDITION OF PUBLIC PROPERTY
14 1 Was the Property at the left side junction of Southbound US-101 / SR-85 ina
15 dangerous condition at the time of the injury?
16 Yes No
17 If your answer to question J is yes, then answer the next question. If your answer to
18 question | is no, stop here, answer no further questions, and have the presiding juror sign and
19 date this form.
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21 2. Did the dangerous condition create a reasonably foreseeable risk that this kind of
22 injury would occur?
23 Yes No
24 If your answer to question 2 is yes, then answer the next question. If your answer to question 2 is
25 no, stop here, answer no further questions, and have the presiding juror sign and date this form.
26 thf
27 ttf
28 Sf
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SPECIAL VERDICT FORM - CASE NO. 19CV346663
3 Did Caltrans have notice of the dangerous condition for a long enough time for
Caltrans to have protected against it?
Yes no V.
If your answer to question 3 is ves, then answer the next question. If your answer to question 3 is
no, stop here, answer no further questions, and have the presiding juror sign and date this form.
4 Was the dangerous condition a substantial factor in causing Walter Huang’s death?
Yes No
If your answer to question 4 is yes, then answer the next question. If your answer to question 4 is
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no, stop here, answer no further questions, and have the presiding juror sign and date this form.
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12 5 When you consider the likelihood and seriousness of potential injury, compared
13 with (a) how much time and opportunity Caltrans had to take action, and (b) the practicality and
14 cost of protecting against the risk of injury, was Caltrans’ failure to take sufficient steps to protect
15 against the risk of injury created by the dangerous condition reasonable under the circumstances?
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Yes No
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If your answer to question 5 is no, then answer the next question. If your answer to question 5 is
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yes, stop here, answer no further questions, and have the presiding juror sign and date this form.
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20 PRODUCT LIABILITY
21 6 Did the 2017 Model X fail to perform as safely as an ordinary consumer would
22 have expected when used or misused in an intended or reasonably foreseeable way?
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Yes No
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If your answer to Question 6 is yes, then proceed to the next question. If your answer to Question
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6 is_no, go directly to Question 8.
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27 Was the 2017 Model X’s design a substantial factor in causing Walter Huang’s
28 death?
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SPECIAL VERDICT FORM - CASE NO. 19CV346663
Yes No
Proceed to the next question regardless of your answer.
COMPARATIVE FAULT
8 Was Walter Huang negligent?
Yes No
If your answer to question 8 is yes, then answer the next question. If your answer to question 8 is
no, then go directly to Question 16.
10 9 Was Waiter Huang’s negligence a substantial factor in causing his death?
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Yes No
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Proceed to the next question regardless of your answer.
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14 DAMAGES
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10. What are Sevonne Huang, Trinity Huang and Tristan Huang’s economic damages?
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17 @ Past financial support that"Walter Huang would have contributed to the
18 family from March 23, 2098 to today:
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21 () Future financial support that Walter Huang would have contributed to the
22 family from today until the end of his life expectancy:
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25 (c) Past houschold services that Walter Huang would have provided from
26 March 23, 2018 to today:
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SPECIAL VERDICT FORM - CASE NO. 19CV346663
@ Future household services that Walter Huang would have provided from
today until the end of his life expectancy:
Proceed to the next question.
IL. What is the total lump sum of noneconomic damages for all Plaintiffs:
10 The amount on the line above must equal the sum of lines a(1) +a(2) + b(1) +b(2) +c(1) +c(2).
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What are Plaintiff Sevonne Huang’s noneconomic damages?
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a) The loss of Walter Huang’s love, companionship, comfort, care,
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assistance, protection, affection, society, moral support, training and guidance from.
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March 23, 2018 to today:
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Q) The loss of Walter Huang’s love, companionship, comfort, care,
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assistance, protection, affection, society, moral support, training and guidance from
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today to the end of his life expectancy:
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Proceed to the next question.
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24 What are Plaintiff Trinity Huang’s noneconomic damages?
25 (1) The loss of Walter Huang’s love, companionship, comfort, care,
26 assistance, protection, affection, society, moral support, training and guidance from
27 March 23, 2018 to today:
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SPECIAL VERDICT FORM - CASE NO. 19CV346663
(2) The loss of Walter Huang’s love, companionship, comfort, care,
assistance, protection, affection, society, moral support, training and guidance from
today to the end of his life expectancy:
$
Proceed to the next question.
Cc. What are Plaintiff Tristan Huang’s noneconomic damages?
10 q The loss of Walter Huang’s love, companionship, comfort,
11 care, assistance, protection, affection, society, moral support, training
12 and guidance from March 23, 2018 to today:
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§
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(2) The loss of Walter Huang’s love, companionship, comfort,
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care, assistance, protection, affection, society, moral support, training
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and guidance from today to the end of his life expectancy:
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Proceed to the next question.
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SPECIAL VERDICT FORM - CASE NO. 19CV346663
12. For each party for whom you made a finding of fault what percentage.of fault do
you assign to them ( for any party to whom you make no finding of fault, enter “0” )
Your assigned percentages must add up to 100%.
DEFENDANT CALTRANS %
TESLA INC. %
WALTER HUANG %
TOTAL: 100% *-
(eDnereD. x URD |
Signed: 5 d|
Presiding Juror
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Dated: (a3 [2034
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After this verdict form has been signed, please notify the court attendant.
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SPECIAL VERDICT FORM - CASE NO. 19CV346663
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SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA SZ HUA HUANG, Individually and as Case No, 19CV346663 successor in interest to WEI LUN HUANG, deceased; TRINITY HUANG, a minor; SPECIAL VERDICT FORM TRISTAN HUANG, a minor, Vv. Plaintiffs, FILE THE STATE OF CALIFORNIA, MAY 2 8 2024 Tk of the Court 10 Defendants. BY. Lex secomara Santa Cara ————____DePuty Il 12 We answer the questions submitted to us as follows: 13 DANGEROUS CONDITION OF PUBLIC PROPERTY 14 1 Was the Property at the left side junction of Southbound US-101 / SR-85 ina 15 dangerous condition at the time of the injury? 16 Yes No 17 If your answer to question J is yes, then answer the next question. If your answer to 18 question | is no, stop here, answer no further questions, and have the presiding juror sign and 19 date this form. 20 21 2. Did the dangerous condition create a reasonably foreseeable risk that this kind of 22 injury would occur? 23 Yes No 24 If your answer to question 2 is yes, then answer the next question. If your answer to question 2 is 25 no, stop here, answer no further questions, and have the presiding juror sign and date this form. 26 thf 27 ttf 28 Sf 1 SPECIAL VERDICT FORM - CASE NO. 19CV346663 3 Did Caltrans have notice of the dangerous condition for a long enough time for Caltrans to have protected against it? Yes no V. If your answer to question 3 is ves, then answer the next question. If your answer to question 3 is no, stop here, answer no further questions, and have the presiding juror sign and date this form. 4 Was the dangerous condition a substantial factor in causing Walter Huang’s death? Yes No If your answer to question 4 is yes, then answer the next question. If your answer to question 4 is 10 no, stop here, answer no further questions, and have the presiding juror sign and date this form. 11 12 5 When you consider the likelihood and seriousness of potential injury, compared 13 with (a) how much time and opportunity Caltrans had to take action, and (b) the practicality and 14 cost of protecting against the risk of injury, was Caltrans’ failure to take sufficient steps to protect 15 against the risk of injury created by the dangerous condition reasonable under the circumstances? 16 Yes No 17 If your answer to question 5 is no, then answer the next question. If your answer to question 5 is 18 yes, stop here, answer no further questions, and have the presiding juror sign and date this form. 19 20 PRODUCT LIABILITY 21 6 Did the 2017 Model X fail to perform as safely as an ordinary consumer would 22 have expected when used or misused in an intended or reasonably foreseeable way? 23 Yes No 24 If your answer to Question 6 is yes, then proceed to the next question. If your answer to Question 25 6 is_no, go directly to Question 8. 26 7 27 Was the 2017 Model X’s design a substantial factor in causing Walter Huang’s 28 death? 2 SPECIAL VERDICT FORM - CASE NO. 19CV346663 Yes No Proceed to the next question regardless of your answer. COMPARATIVE FAULT 8 Was Walter Huang negligent? Yes No If your answer to question 8 is yes, then answer the next question. If your answer to question 8 is no, then go directly to Question 16. 10 9 Was Waiter Huang’s negligence a substantial factor in causing his death? 11 Yes No 12 Proceed to the next question regardless of your answer. 13 14 DAMAGES 15 10. What are Sevonne Huang, Trinity Huang and Tristan Huang’s economic damages? 16 17 @ Past financial support that"Walter Huang would have contributed to the 18 family from March 23, 2098 to today: 19 20 21 () Future financial support that Walter Huang would have contributed to the 22 family from today until the end of his life expectancy: 23 24 25 (c) Past houschold services that Walter Huang would have provided from 26 March 23, 2018 to today: 27 28 3 SPECIAL VERDICT FORM - CASE NO. 19CV346663 @ Future household services that Walter Huang would have provided from today until the end of his life expectancy: Proceed to the next question. IL. What is the total lump sum of noneconomic damages for all Plaintiffs: 10 The amount on the line above must equal the sum of lines a(1) +a(2) + b(1) +b(2) +c(1) +c(2). 11 What are Plaintiff Sevonne Huang’s noneconomic damages? 12 a) The loss of Walter Huang’s love, companionship, comfort, care, 18 assistance, protection, affection, society, moral support, training and guidance from. 14 March 23, 2018 to today: 15 16 17 Q) The loss of Walter Huang’s love, companionship, comfort, care, 18 assistance, protection, affection, society, moral support, training and guidance from 19 today to the end of his life expectancy: 20 21 22 Proceed to the next question. 23 24 What are Plaintiff Trinity Huang’s noneconomic damages? 25 (1) The loss of Walter Huang’s love, companionship, comfort, care, 26 assistance, protection, affection, society, moral support, training and guidance from 27 March 23, 2018 to today: 28 4 SPECIAL VERDICT FORM - CASE NO. 19CV346663 (2) The loss of Walter Huang’s love, companionship, comfort, care, assistance, protection, affection, society, moral support, training and guidance from today to the end of his life expectancy: $ Proceed to the next question. Cc. What are Plaintiff Tristan Huang’s noneconomic damages? 10 q The loss of Walter Huang’s love, companionship, comfort, 11 care, assistance, protection, affection, society, moral support, training 12 and guidance from March 23, 2018 to today: 18 § 14 (2) The loss of Walter Huang’s love, companionship, comfort, 15 care, assistance, protection, affection, society, moral support, training 16 and guidance from today to the end of his life expectancy: 17 18 19 20 Proceed to the next question. 21 22 23 24 25 26 27 28 5 SPECIAL VERDICT FORM - CASE NO. 19CV346663 12. For each party for whom you made a finding of fault what percentage.of fault do you assign to them ( for any party to whom you make no finding of fault, enter “0” ) Your assigned percentages must add up to 100%. DEFENDANT CALTRANS % TESLA INC. % WALTER HUANG % TOTAL: 100% *- (eDnereD. x URD | Signed: 5 d| Presiding Juror 10 11 12 Dated: (a3 [2034 13 After this verdict form has been signed, please notify the court attendant. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6 SPECIAL VERDICT FORM - CASE NO. 19CV346663