Denis, John, Neill & Joe Wagner v Nine Network & Nicholas Cater Questions for the Jury Question 1: Have the plaintiffs (Denis, John, Neill and Joe Wagner) established that the 60 Minutes program conveyed to the ordinary reasonable viewer the following imputations (or any imputation which is not substantially different from them): {a) The plaintiffs caused a man-made disaster, the deaths of 12 people, including an infant, as well as incomprehensible grief, ‘trauma and devastation, by failing to take steps that they should have to prevent a controversial quarry wall they owned from collapsing, and causing the catastrophic flood that devastated the town of Grantham (FeB{No (b) The plaintifs had sought to conceal the truth from becoming known about the role their quarry played in causing the catastrophic flood that devastated the town of Grantham @INo (c) The plaintiffs had disgracefully refused to answer to the public for their failure to take steps they should have taken to prevent a quarry wall on property they owned from collapsing and causing the catastrophic flood that devastated the town of (E3INo Grantham If you answered “Yes” to any part of question 1, answer the corresponding part of question 2. If you answered “No” to every part of question 1, go to question 3. Question 2 Have the plaintiffs established that any imputation you found to have been conveyed (and recorded a "Yes" at question 1) was defamatory of them? (a) The plaintiffs caused a man-made disaster, the deaths of 12 people, including an infant, as well as incomprehensible grief, trauma and devastation, by failing to take steps that they should have to prevent a controversial quarry wall they owned from collapsing, and causing the catastrophic flood that devastated the town of Grantham Yes)No (0) The plaintifs had sought to conceal the truth from becoming known about the role their quarry played in causing thecatastrophic flood that devastated the town of Grantham (WeaNo The plaintiffs had disgracefuly refused to answer to the public for their failure to take steps they should have taken to prevent a quarry wall on property they owned from collapsing and causing the catastrophic flood that devastated the town of e3No Grantham i ‘Admitted facts for the purpose of question 3: Denis, John, Neill and Joe are brothers and members of the Wagner family. At the time that the 60 Minutes program was broadcast and at the time of the January 2011 flood, they were the owners and operators of the company known as ‘Wagners’. Part of the Wagners business included quarry operations carried out at the quarry near Grantham, as shown in the 60 Minutes program, and the quarry ‘was owned by the Wagners at the time of the January 2011 flood. Question 3 Have the plaintiffs established that the words spoken by Nicholas Cater in the 60 Minutes program would have conveyed to an ordinary reasonable viewer who knew the admitted facts the following imputation (or an imputation not substantially different): (a) The plaints caused a man-made disaster, a catastrophic flood which destroyed the town of Grantham and killed 12 people, by faling to take steps they should have taken to prevent a quarry wall on property they owned from collapsing, causing a devastating wall of water to enguif the town of Grantham (WesIno lt you answered “Yes” to question 3 go to question 4 If you answered “No” to question 3, there are no further questions to be answered. Question 4 Have the plaintiffs established that the imputation at question 3 was defamatory of them? (a) The plaintiffs caused a man-made disaster, a catastrophic flood which destroyed the town of Grantham and kiled 12 people, by failing to take steps they should have taken to prevent a quarry wall on property they owned from collapsing, causing a devastating wall of water to engulf the town of Grantham (WesINo 2