10.05 [1983 New] Damages-Exemplary-Strict Liability-Both Product Defect and Failure to Warn Submitted

Instruction No 1 10.05 [1983 New] Damages--Exemplary--Strict Liability--Both Product Defect and Failure to Warn Submitted (here insert First, if you find in favor of plaintiff under Instruction Number number of plaintiff's verdict directing instruction MAI 25.04) and if you believe that at the time defendant sold the (describe product) defendant knew of the defective condition and danger submitted in Instruction Number (here insert number of plaintiff's verdict directing instruction MAI 25.04), or (here insert number if you find in favor of plaintiff under Instruction Number of plaintiff's verdict directing instruction MAI 25.05) and if you believe that at the time defendant sold the (describe product) defendant knew of the danger submitted in Instruction Number (here insert number of plaintiff's verdict directing instruction MAI 25.05), and Second, if you believe that defendant, in one or more of the respects submitted in paragraph First, 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 (here insert number of plaintiff's damage instruction) you may Instruction Number 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.