Ill. Pattern Jury Instr. (Civil) 190.03

The plaintiff has the burden of proving each of the following propositions:

[First, that _____________________ was injured and sustained damages [while

name of resident

_____________________ was a resident of ___________________________];

name of resident name of facility

[Second, that the defendant[s] [were] [was] the [owner] [and] [licensee] of a covered

facility];

Third, that the defendant[s] [negligently] [and] [or] [intentionally] violated the Nursing

Home Care Act in one of the ways claimed by the plaintiff as stated to you in these instructions;

Fourth, that the defendant’s violation of the Nursing Home Care Act was a proximate cause

of the injury to the plaintiff.

If you find from your consideration of all the evidence that each of these propositions has

been proved, then your verdict should be for the plaintiff. On the other hand, if you find from your

consideration of all of the evidence that any of these propositions has not been proved, then your

verdict should be for the defendant.

Instruction and Notes approved May 2014.