Ill. Pattern Jury Instr. (Civil) 120.10

[In Count __], the minor plaintiff, [plaintiff's name], by [guardian's name], his/her

Guardian, seeks to recover damages from defendant [defendant's name]. In order to recover

damages, the plaintiff has the burden of proving:

First, the defendant knew, or in the exercise of ordinary care, should have known, that

children frequented defendant's [property] [land] [building] [other].

Second, there was a [condition] [activity] on defendant's [property] [land] [building]

[other] that prese nted a risk of harm to children that they would not appreciate due to their

immaturity.

Third, the expense or inconvenience to the defendant in protecting children against the

[condition] [activity] would be slight in comparison to the risk of harm to the m, and that in

(failing to act) (acting) the defendant was negligent in one or more of the following ways:

a) ________,

b) ________,

c) ________,

Fourth, the minor plaintiff was injured.

Fifth, the [condition] [activity] was a proximate cause of the injury or damage to the

minor plaintiff.