Free Proposed Jury Instructions - District Court of Arizona - Arizona

EXHIBIT 1

Case 2:03-cv-02343-DGC

Document 152-2

Filed 01/05/2006

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Plaintiff's Proposed Non-Model Jury Instruction No. 1
STATEMENT OF CLAIM; DEFINITION OF FAULT; DEFINITION OF NEGLIGENCE (NO COMPARATIVE FAULT) Cheryl Allred claims that Corrections Corporation of America was at fault. Fault is negligence that was a cause of Cheryl Allred's injury. Negligence is the failure to use reasonable care. Negligence may consist of action or inaction. Negligence is the failure to act as a reasonably careful person would act under the circumstances. SOURCE: RAJI (CIVIL) 3d Fault 1; A.R.S. § 12-2506(F)(2).

________ Given ________ Refused ________ Modified

Case 2:03-cv-02343-DGC

Document 152-2

Filed 01/05/2006

Page 2 of 5

Plaintiff's Proposed Non-Model Jury Instruction No. 2
DEFINITION OF CAUSATION (NO COMPARATIVE FAULT) Before you can find Corrections Corporation of America at fault, you must find that Corrections Corporation of America's negligence was a cause of Plaintiff Cheryl Allred's injury. Negligence causes an injury if it helps produce the injury and if the injury would not have happened without the negligence. SOURCE: RAJI (CIVIL) 3d Fault 2; McDowell v. Davis, 104 Ariz. 69, 448 P.2d 869 (1968); Porterie v. Peters, 111 Ariz. 452, 532 P.2d 514 (1975).

________ Given ________ Refused ________ Modified

Case 2:03-cv-02343-DGC

Document 152-2

Filed 01/05/2006

Page 3 of 5

Plaintiff's Proposed Non-Model Jury Instruction No. 3
STATEMENT OF LIABILITY ISSUES (NO COMPARATIVE FAULT) If you find that Corrections Corporation of America was not at fault, then your verdict must be for Corrections Corporation of America. If you find that Corrections Corporation of America was at fault, then Corrections Corporation of America is liable to Plaintiff Cheryl Allred and your verdict must be for Plaintiff Cheryl Allred. SOURCE: RAJI (CIVIL) 3d Fault 4.

________ Given ________ Refused

Case 2:03-cv-02343-DGC

Document 152-2

Filed 01/05/2006

Page 4 of 5

________ Modified

Case 2:03-cv-02343-DGC

Document 152-2

Filed 01/05/2006

Page 5 of 5