Ill. Pattern Jury Instr. (Civil) 13.02

[As to Count ____,] The defendant has raised the affirmative defense that the plaintiff

assumed the risk of injury from the danger which the plaintiff claims caused his injury. To prove

this defense, the defendant has the burden of proving each of the following propositions:

First, that at the time of the occurrence in question, the plaintiff was the defendant's

employee;

Second, that performing the duties of his employment exposed the plaintiff to the da nger

that resulted in the injury of which he complains[,] [namely, describe danger];

Third, that the danger was one that ordinarily accompanies the employment;

Fourth, that the plaintiff had actual knowledge of this danger and understood and

appreciated the nature and extent of the risk;

Fifth, that the plaintiff voluntarily subjected himself to this danger; and

Sixth, that this danger was the cause of the plaintiff's [alleged] [injuries] [damages].

If you decide that each of these propositions has been proved, then your verdict should be

for the defendant [as to Count ____]. If, on the other hand, you decide that any of these

propositions has not been proved, then the defendant has not proved the affirmative defense of

assumption of the risk.