Case 3:18-cv-02862-M Document 256 Filed 11/20/24
Page 3 of 7 PageID 7099
3. Question 3: Compensatory Damages
What sum of money, if any, would compensate Plaintiffs for injuries they suffered as a result of
Defendant’s conduct?
Claims of Estate of Botham Jean
(a) Mental anguish experienced by Botham Jean
between the time he was shot and his death:
$
2,000,000
(b) Loss of net future earnings by Botham Jean:
$
5,500,000
(c) Loss of Botham Jean’s capacity to enjoy life:
2,750,000
Claims of Allison and Bertrum Jean
(a) The value of the loss of companionship and society
sustained from September 6, 2018, to today
to Allison Jean:
(b) The value of the loss of companionship and society
that, in reasonable probability, will be sustained from
today forward
to Allison Jean:
(c) The value of the mental anguish sustained from
September 6, 2018, to today
500,000
2,000,000
to Allison Jean:
(d) The value of the mental anguish that, in reasonable
probability, will be sustained from today forward
to Allison Jean:
3
$
6,000,000
5,700,000

After House Speaker Mike Johnson indicated support for Republic proposal preventing Trans Congresswoman elected from Delaware Sarah McBride from using women’s restrooms in the Capitol , McBride said that she will use the men’s restroom on Capitol Hill. In her statement, she said that she is not here to fight about bathrooms but to fight for Delawareans.
She added, “I’m not here to fight about bathrooms. I’m here to fight for Delawareans and to bring down costs facing families. Like all members, I will follow the rules as outlined by Speaker Johnson, even if I disagree with them.”

She further said, “This effort to distract from the real issues facing this country hasn’t distracted me over the last several days, as I’ve remained hard at work preparing to represent the greatest state in the union come January.”
She stated, “Serving in the 119th Congress will be the honor of a lifetime and I continue to look forward to getting to know my future colleagues on both sides of the aisle. Each of us were sent here because voters saw something in us that they value. I have loved getting to see those qualities in the future colleagues that I’ve met and I look forward to seeing those qualities in every member come January. I hope all of my colleagues will seek to do the same with me.”
House Speaker Mike Johnson indicated support on Tuesday for a Republican proposal to prevent Representative-elect Sarah McBride, the first transgender woman elected to Congress, from using women’s restrooms in the Capitol. This restriction would take effect when McBride assumes office next year.
“We’re not going to have men in women’s bathrooms,” Johnson told The Associated Press. “I’ve been consistent about that with anyone I’ve talked to about this.”
The proposal, introduced by Republican Representative Nancy Mace of South Carolina, aims to prohibit lawmakers and House employees from “using single-sex facilities other than those corresponding to their biological sex.” Mace confirmed that the bill specifically targets McBride, who recently won the election in Delaware.
Democrats, including McBride, criticized the Republican initiative, labeling it as “bullying” and a “distraction.”
“This is a blatant attempt from far right-wing extremists to distract from the fact that they have no real solutions to what Americans are facing,” McBride said. “We should be focused on bringing down the cost of housing, health care, and child care, not manufacturing culture wars.”
The debate surrounding bathroom access for transgender individuals has gained significant traction nationwide and was a key point in President-elect Donald Trump’s campaign. Currently, at least 11 states have enacted legislation barring transgender girls and women from using female restrooms in public schools and, in certain instances, other government facilities.
Despite potential challenges, Mace expressed her determination to proceed. “If it’s not,” she said. “I’ll be ready to pick up the mantle.”

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Indian billionaire Gautam Adani has been charged by federal prosecutors in New York in connection with an alleged years-long scheme to bribe Indian officials in exchange for favourable terms on solar power contracts projected to bring in more than $2bn in profit.

The 62-year-old tycoon, who chairs the multinational conglomerate Adani Group and has been a vocal supporter of Prime Minister Narendra Modi, was indicted in Brooklyn on charges including securities fraud alongside seven others, including executives of Adani energy subsidiaries and former employees of a Canadian pension fund.

His nephew Sagar Adani, who is the executive director at a renewables company founded by Gautam Adani, is also among the defendants.

US prosecutors said more than $250mn in bribes were paid between 2020 and 2024 to people in the Indian government as part of the scheme, which was allegedly concealed from the US banks and investors from which they raised billions of dollars.

They claimed that Gautam Adani met with an Indian official to “advance” the scheme.

The US attorney’s office in Brooklyn also charged three former employees of large Canadian pension fund CDPQ in connection with the alleged scheme, saying they obstructed an investigation into the bribes by deleting emails and agreeing to provide false information to the US government. CDPQ, which invests in infrastructure projects, is a shareholder in Adani companies.

The indictments threaten to reignite a reputational crisis for Adani Group, which has been trying to move past claims of accounting fraud and stock market manipulation made last year by US short seller Hindenburg Research.

“This indictment alleges schemes to pay over $250 million in bribes to Indian government officials,” US deputy assistant attorney-general Lisa Miller said. “These offences were allegedly committed by senior executives and directors to obtain and finance massive state energy supply contracts through corruption and fraud at the expense of US investors.”

Prosecutors further alleged that the defendants “extensively documented their corrupt efforts” on mobile phones, on PowerPoint presentations and in Excel spreadsheets “that summarised various options for paying and concealing bribe payments”.

In a parallel civil lawsuit, the US Securities and Exchange Commission said the alleged bribes were paid in order to “secure [the Indian government’s] commitment to purchase energy at above-market rates that would benefit Adani Green and Azure Power”, two renewable energy companies in India.

Adani Green, which is building one of the largest solar plants in the world at Khavda in India’s western state of Gujarat, raised more than $175mn from US investors as part of a $750mn corporate bond while the scheme was ongoing, US regulators said.

Gautam Adani and Sagar Adani allegedly “induced US investors to buy Adani Green bonds through an offering process that misrepresented not only that Adani Green had a robust anti-bribery compliance programme but also that the company’s senior management had not and would not pay or promise to pay bribes”, said Sanjay Wadhwa, acting director at the SEC’s enforcement division. 

According to the regulator’s complaint, Sagar Adani allegedly told Azure executives and others about “incentives”, or bribes, he had been proposing to “motivate” state officials to agree contracts with the Indian government’s arm responsible for implementing renewable energy programmes.

Adani and Azure did not immediately respond to requests for comment.

In a statement, CDPQ said: “CDPQ is aware of charges filed in the US against certain former employees. Those employees were all terminated in 2023 and CDPQ is co-operating with US authorities. In light of the pending cases, we have no further comment at this time.”

The Indian group’s founder has over the past two decades built Adani into one of India’s most formidable industrial groups, diversifying from its core ports and trading business into mining, airports, coal and renewable power.

Outside India it has built or bid for power, port and other infrastructure projects in several countries, including Bangladesh, Sri Lanka, and Israel, where it operates the port of Haifa.

In a post on X congratulating Donald Trump on his US election victory earlier this month, Adani said his group was “committed to leveraging its global expertise” and would invest $10bn in American energy security and infrastructure projects as part of the partnership between India and the US, with the aim of creating up to 15,000 jobs.

Adani’s rise in business, first in Gujarat then nationally, has coincided with the Indian state’s drive to harness private-sector expertise and capital to develop neglected transport and other infrastructure, which has accelerated during Modi’s decade in power.

As shares of his listed companies rose, in 2022 Adani briefly overtook rival billionaire Mukesh Ambani to become Asia’s richest man. 

The Indian National Congress party’s Rahul Gandhi, who became India’s opposition leader after this year’s general election, called for an investigation after the Hindenburg allegations and questioned Adani’s record of winning government tenders, as well as his close ties with ruling politicians including Modi, who is also from Gujarat.

The Adani Group dismissed the Hindenburg report as an “attack on India” and has repeatedly denied wrongdoing. His companies’ share prices have since rebounded.