MUJI 2d CV202A

You must decide whether [names of persons on the verdict form] were negligent.

Negligence means that a person did not use reasonable care. We all have a duty to use reasonable care to avoid injuring others. Reasonable care is simply what a reasonably careful person would do in a similar situation. A person may be negligent in acting or in failing to act.

The amount of care that is reasonable depends upon the situation. Ordinary circumstances do not require extraordinary caution. But some situations require more care because a reasonably careful person would understand that more danger is involved.

To establish negligence, [name of plaintiff] has the burden of proving that:

(1) [name of defendant] was negligent; and

(2) this negligence was a cause of [name of plaintiff]'s harm.

In this action, [name of plaintiff] alleges that [name of defendant] was negligent in the following respects:

(1)

(2)

(3)

If you find that the [name of defendant] was negligent in any of these respects, then you must determine whether that negligence was a cause of [name of plaintiff]'s harm.

[[Name of defendant] claims that [name of plaintiff] was negligent in causing [his] own harm. To establish [name of plaintiff]'s negligence, [name of defendant] has the burden of proving that:

(1) [name of plaintiff] was negligent; and

(2) this negligence was a cause of [name of plaintiff]'s harm.

In this action, [name of defendant] alleges that [name of plaintiff] was negligent in the following respects:

(1)

(2)

(3)

If you find that the [name of plaintiff] was negligent in any of these respects, then you must determine whether that negligence was a cause of [his] harm.]