Ill. Pattern Jury Instr. (Civil) 800.09B

Concealment--One Plaintiff and One Defendant--Clear and Convincing Evidence

The plaintiff has the burden of proving each of the following propositions by clear and

convincing evidence:

First, the defendant knowingly [concealed] [withheld] from the plaintiff [a] material

fact[s];

Second, that the defendant [concealed] [withheld] the fact[s] with the intent to deceive

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

Third, the plaintiff [acted] [describe what the plaintiff d id, e.g., “bought the farm”] in

justifiable reliance on the facts as he knew them;

Fourth, the plaintiff's damages resulted from the [concealment] [withholding] of [a]

material fact[s] by the defendant.

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

been proved by clear and convincing evidence, then your verdict should be for the plaintiff. On

the other hand, if you find from your consideration of all the evidence that any of these

propositions has not been proved by clear and convincing evidence, then your verdict should be

for the defendant.