We, the jury, answer the questions submitted to us as follows:

1. As to each defendant listed below, answer the following question: Did defendant(s) remove, or participate in making the decision to remove Rafaelina Duval’s child from her care without first obtaining a warrant?

If any of your answers to question 1 is “yes,” as to any defendant, then answer question 2. If you answered “no,” to all defendants then skip to question number 13.

2. Have Defendants proven that, at the time they seized the child, they possessed specific and articulable facts to show that RafaelinaDuval’s son was likely to experience serious bodily harm in the time it would take to obtain a warrant?

If any of your answers to question 2 is “yes,” as to any defendant, then answer question 3. If you answered “no,” to all defendants then skip to question number 4.

3. Have Defendants proven that the removal of Rafaelina Duval’s son from her care without first obtaining a warrant was reasonably necessary to avert a specific injury on November 3, 2009.

If your answer to question number 3 is “yes,” then skip to question number 13. If you answered “no,” then answer question number 4.

4. Was the removal of Rafaelina Duval’s child from her care without first obtaining a warrant a substantial factor in causing harm to Rafaelina Duval?

If your answer to question 4 is “yes,” then answer question 6. If you answered “no,” then skip to question number 13.

5. As to any defendant as to whom you answered “yes” to question number 1 did that defendant engage in the conduct with malice, oppression, or fraud?

Answer question number 6.

6. Did the County of Los Angeles Department of Children and Family Services (hereafter “DCFS”) have an official custom and/or practice of seizing children from their parents without a warrant?

Answer question number 7.

7. Did DCFS fail to enact an official policy or procedure when it should have done so?

If your answer to question 6 or 7 is “yes,” then answer question 8. If you answered “no” to both 6 and 7, then skip to question number 10.

8. Did DCFS know, because of a pattern of similar violations, or should it have been obvious to it, that its official customs or practices, or failure to enact an official policy or procedure was likely to result in the violation of a parent’s right to be free of unwarranted seizures of their children?

If your answer to question number 8 is “yes,” then answer question number 9. If your answer to question number 8 is “no,” then skip to question number 10.

9. Did either Susan Pender or Kimberly Rogers act because of this official custom or practice, or lack of policy or procedure.

Answer question # 10.

10. Was DCFS’s training program and/or supervision of its employees inadequate to train and/or supervise its employees to properly handle usual and recurring situations?

If your answer to question 10 is “yes,” then answer question 11. If you answered “no,” then skip to question number 13.

11. Did the DCFS know because of a pattern of similar violations, or should it have been obvious to it, that its inadequate training program and/or supervision of its employees was likely to result in the removal Rafaelina Duval’s child from her care without first obtaining a warrant?

If your answer to question 11 is “yes,” then answer question 12. If you answered “no,” then skip to question number 13.

12. Was the failure to provide adequate training and/or supervision a substantial factor in causing harm to Rafaelina Duval?

Proceed to question number 13.

13. Was the conduct of Victoria Scheele outrageous?

If you answered “yes,” then answer question 14. If you answered “no,” But answered yes to question number 4, then skip to question number 18. If you answered “no” both this question and question number 4 then sign and return this verdict form.

14. Did Victoria Scheele intend to cause Rafaelina Duval emotional distress, or act with reckless disregard of the probability that RafaelinaDuval would suffer emotional distress?

If you answered “yes,” then answer question 15. If you answered “no,” but answered yes to question number 4, then skip to question number 18. If you answered “no” to both this question and question number 4 then sign and return this verdict form.

15. Did Rafaelina Duval suffer severe emotional distress?

If any of your answers to question 15 is “yes,” then answer question 16. If you answered “no,” then skip to question number 18.

16. Was Defendant Victoria Scheele’s conduct a substantial factor in causing Rafaelina Duval’s severe emotional distress?

If your answer to question 16 is “yes,” then answer question 17. If you answered “no,” then skip to question number 18.

17. Did Victoria Scheele engage in the conduct with malice, oppression, or fraud?

Answer question number 18.

18. If you answered “yes” to question number 4, then answer questions A and B. If you answered “yes” to question 16 then answer questions C and D. If you answered “yes” to both questions then answer questions A through D.

What are Rafaelina Duval’s damages?

A. Past Non-Economic Damages: Enter the amount below that you find that either Defendant Kimberly Rogers or Susan Pender or County of Los Angeles DCFS are liable for the unwarranted seizure of baby Ryan.

B. Future Non-Economic Damages: Enter the amount below that you find that either Defendant Kimberly Rogers or Susan Pender or County of Los Angeles DCFS are liable for the unwarranted seizure of baby Ryan.

What are Rafaelina Duval’s damages?

C. Past Non-Economic Damages: Enter the amount below that you find that Defendant Victoria Scheele is liable for intentional infliction of emotional distress.

D. Future Non-Economic Damages: Enter the amount below that you find that Defendant Victoria Scheele is liable for intentional infliction of emotional distress.

Subtotal for Intentional Infliction of Emotional Distress

TOTAL DAMAGES: $ 2,940,000

Signed: <<signature>>

Presiding Juror

Dated: 11/3/2016

(After all verdict forms have been signed, this verdict form must be delivered to the Court attendant.)