CJI-Civ. 6:9

The plaintiff, (name), claims damages from the defendant, (name), for (injuries)

(damages) (losses) caused by (a) (an) (insert appropriate description of event, e.g., “auto

accident on June 24, 20--”). If you find that the defendant’s (insert appropriate description,

e.g., “negligence”), if any, was a cause of any such (injuries) (damages) (losses), then the

plaintiff may recover all damages caused by that event. But if you find the plaintiff was

later injured in (a) (an) (insert appropriate description of second event, e.g., “toboggan

accident on January 3, 20--”) which was not caused by any acts or omissions of the

defendant, then the plaintiff may not recover any damages caused only by the (insert

description of second event, e.g., “toboggan accident”).

If you find the (insert description of second event, e.g., “toboggan accident on January

3, 20--”) (increased) (aggravated) (worsened) any (injuries) (damages) (losses) caused by

the (insert description of first event, e.g., “auto accident on June 24, 20--”), then you must

separate, if possible, those damages caused by the (description of first event, e.g., “auto

accident”) from those caused by the (description of second event, e.g., “toboggan accident”),

and the plaintiff may recover all those separate damages caused by the (description of first

event, e.g., “auto accident”).

If it is not possible to separate any damages caused by the (description of first event,

e.g., “auto accident on June 24, 20--”) from any caused by the (description of second event,

e.g., “toboggan accident on January 3, 20--”), then the plaintiff may recover those damages

only from the date of the (description of first event, e.g., “auto accident on June 24, 20--”) to

the date of the (description of second event, e.g., “toboggan accident on January 3, 20--”).