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] [damaged] and [his property was damaged];

        3.    That the negligence of the defendant was a proximate cause of [injuries] [and] [damages] [property damages]; and

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

        In this case defendant has asserted the affirmative defense that the plaintiff was negligent. Defendant has the burden of proving each of the following propositions:

        1.    That the plaintiff was negligent;

        2.    That the negligence of the plaintiff was a proximate cause of the [injury] [damage] [and] [property damage] claimed to have been suffered by the plaintiff.

IDJI 271.

GIVEN ______________

REFUSED ____________

MODIFIED ___________

COVERED ____________

OTHER ______________