25.10(A) [1990 New] Verdict Directing-Negligently Supplying Dangerous Instrumentality

Instruction No 1 25.10(A) [1990 New] Verdict Directing--Negligently Supplying Dangerous Instrumentality Your verdict must be for plaintiff if you believe: First, defendant supplied (here describe instrumentality supplied, such as automobile, hair dye, etc. ) for use, and Second, the (describe instrumentality ) (here describe defect or hazard such as "had a wheel constructed with improperly tempered steel which had a propensity to break"; "included an ingredient which would cause systemic damage in certain persons", etc. ) and was therefore dangerous when put to a reasonably expected use, and Third, the (describe instrumentality ) was put to a reasonably expected use, and Fourth, defendant had no reason to believe that those for whose use the (describe instrumentality ) was supplied would realize its dangerous condition, and Fifth, defendant knew or had information from which defendant, in the exercise of ordinary care, should have known of such dangerous condition, and Sixth, defendant failed to adequately warn of such dangerous condition, and Seventh, defendant was thereby negligent, and Eighth, as a direct result of such negligence, plaintiff sustained damage. * [unless you believe plaintiff is not entitled to recover by reason of Instruction Number (here insert number of affirmative defense instruction ) ].