10.06 [1983 New] Damages-Exemplary-Both Negligence and Strict Liability Submitted

Instruction No 1 10.06 [1983 New] Damages--Exemplary--Both Negligence and Strict Liability Submitted (here insert If you find in favor of plaintiff under Instruction Number number of plaintiff's verdict directing instruction based on negligence), and if you believe the conduct of defendant as submitted in Instruction Number (here insert number of plaintiff's verdict directing instruction based on negligence) showed complete indifference to or conscious disregard for the safety of others, or (here insert If you find in favor of plaintiff under Instruction Number number of plaintiff's strict liability verdict directing instruction) and if you believe: First, at the time defendant sold the (describe product), defendant knew of the [defective condition and danger] [danger] submitted in Instruction Number (here insert number of plaintiff's strict liability verdict directing instruction), and Second, defendant thereby showed complete indifference to or conscious disregard for the safety of others, then in addition to any damages to which you may find plaintiff entitled under Instruction Number (here insert number of plaintiff's damage instruction) you may award plaintiff an additional amount as punitive damages in such sum as you believe will serve to punish defendant and to deter defendant and others from like conduct.