Usually in a wrongful death case, there is a survivorship claim and a wrongful death claim under N.J.S.A. 2A:31-1. In such a case, the following damage questions are appropriate:
1. Set forth the sum of money that will fairly and reasonably compensate the Estate of [name] for the losses sustained by the decedent while alive due to the defendant's negligence:
a. Lost wages
$
b. Pain, suffering, disability, impairment
and loss of enjoyment of life
$
2. Set forth the sum of money that will fairly and reasonably compensate the survivors of the decedent for the losses sustained by them due to the wrongful death of [name].
a. Medical bills (this sum may not
exceed $ )
$
b. Funeral Expenses (this sum may
not exceed $ )
$
c. Financial losses sustained by the
survivors of the decedent due to the
wrongful death of [name].
$
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Model Civil Jury Charges
