Free Proposed Jury Instructions - District Court of Colorado - Colorado

Case 1:04-cv-00591-MSK-BNB

Document 167-4

Filed 07/18/2005

Page 1 of 1

INSTRUCTION NO._____1 If you find that the negligence of Swift constituted a substantial factor in causing the plaintiff's injuries, you cannot reduce the amount of the award because a subsequent event aggravated plaintiff's injuries.

Webb v. Dessert Seed Company, Inc. 718 P.2d 1057 (Colo. 1986); Scharrrel v. Wal-Mart, 949 P.2d 89 (Colo. 1998); Voight v. Colorado Mountain Club, 819 P.2d 1088 (Colo. App. 1991).

Plaintiff has been unable to contact defense counsel regarding whether he agrees to this instruction. Plaintiff anticipates that Defendant will object to this instruction in its entirety due to Defendant's submission of Instruction 9:20­Cause­Concurrent Cause­Intervening Causes.

1