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31.17 [1992 New] Verdict Directing-Waiver of Sovereign Immunity-Dangerous Condition of Public Entity's Property Created by Employee
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Description
Instruction No 1 31.17 [1992 New] Verdict Directing--Waiver of Sovereign Immunity-- Dangerous Condition of Public Entity's Property Created by Employee Your verdict must be for plaintiff if you believe: First, (here describe condition that made the public entity's property dangerous, such as "there was oil on the gymnasium floor" or "the table saw was unguarded" ), and as a result the defendant's (describe property, such as "gymnasium floor" or "table saw" ) was not reasonably safe, and Second, such condition was created by an employee of (name of public entity ) within the scope and course of employment, and Third, the employee was thereby negligent, and Fourth, as a direct result of such negligence, plaintiff sustained damage. * Number [unless you believe plaintiff is not entitled to recovery by reason of Instruction (here insert number of affirmative defense instruction ) ].