Ill. Pattern Jury Instr. (Civil) 800.01

Pleadings--Fraud--One Defendant

The plaintiff claims that the defendant made the following statement[s]:

[Here insert or paraphrase the allegedly fraudulent statement or statements that the

defendant is claimed to have made.]

The plaintiff further claims that the statement[s] [was a] [were] false statement[s] of

material fact[s].

The plaintiff further claims that the defendant [k new the statement(s) (was) (were) false]

[or] [believed the statement(s) to be false] [or] [made the statement(s) in reckless disregard of

whether (it was) (they were) true or false].

The plaintiff further claims that the defendant made the statement[s] with the intent to

induce the plaintiff to [act] [describe what the plaintiff did, e.g., “buy the farm”].

The plaintiff further claims that he reasonably believed the statement[s] and [acted]

[describe what the plaintiff did, e.g., “bought the farm”] in justifiable reliance on the truth of the

statement[s].

The plaintiff further claims that he sustained damages as the result of his reliance.

The defendant [denies that he made (a) false statement(s) of (a) fact(s),] [denies that any

(claimed) statement (s) (was) (were) material,] [denies that he (knew) (or) (believed) the

(claimed) statement(s) to be false,] [denies that any (claimed) statement(s) (was) (were) made in

reckless disregard of the statement('s) (s') truth or falsity,] [denies that he intende d to induce the

plaintiff to act ([describe what the plaintiff did, e.g., “buy the farm”]),] [denies that the plaintiff

reasonably believed the claimed) statement(s) or (acted) ([describe what the plaintiff did, e.g.,

“bought the farm”] in justifiable reliance on the truth of the statement(s),] [and] [denies that

damage resulted to the plaintiff from his reliance].