INSTRUCTION NO. ________

      The plaintiff has the burden of proving each of the following propositions.

      1.    That the defendant was negligent;

       2.    That [the plaintiff was injured] [and] [his property was damaged];

       3.    That the negligence of the defendant was a proximate cause of [the injury to the plaintiff] [and] [the damage to his property]; and,

       4.    The elements of damage, and the amount thereof.

        If you find from your consideration of all the evidence that each of these propositions has been proved, then your verdict should be for the plaintiff; but, if you find from your consideration of all the evidence that any of these propositions has not been proved, then your verdict should be for the defendant.

IDJI 270.

GIVEN ______________

REFUSED ____________

MODIFIED ___________

COVERED ____________

OTHER ______________