Ill. Pattern Jury Instr. (Civil) 22.01

[Under Count ____,] The plaintiff has the burden of proving each of the following

propositions:

First: That [the plaintiff was injured] [or] [the plaintiff's property was damaged.]

Second: That the [injury [damage] was received from a [name of instrumentality, e.g., a

folding chair] which [was] [had been] under the defendant's [control] [management].

Third: That in the normal course of events, the [injury] [damage] would not have

occurred if the defendant had used ordinary care while the [instrumentality] was under his

[control] [management].

If you find that each of these propositions has been proved, the law permits you to infer

from them that the defendant was negligent with respect to the [instrumentality] while it was

under his control or management.

If you do draw such an inference, and if you further find that the plaintiff's injury was

proximately caused by that negligence, your verdict shall be for the plaintiff under this Count.

On the other hand, if you find that any of these propositions has not been proved, or if you find

that the defendant used ordinary care for the safety of the plaintiff in his [control] [management]

of the [instrumentality], or if you find that the defendant's negligence, if any, was not a

proximate cause of the plaintiff's [injury] [damages], then your verdict shall be for the defendant

under this Count.