10.07 [1991 New] Damages-Exemplary-Modification of MAI 10.02-Submission of Specific Acts and Knowledge

Instruction No 1 10.07 [1991 New] Damages--Exemplary--Modification of MAI 10.02-- Submission of Specific Acts and Knowledge (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 that: First, (here describe the act or omission which justifies the submission of punitive damages), and Second, defendant knew or had information from which defendant, in the exercise of ordinary care, should have known that such conduct created a high degree of probability of injury, and Third, defendant thereby showed complete indifference to or conscious disregard for the safety of others, then in addition to any damages to which you 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.