Fill and Sign the Sam M V Chafee Plaintiffs Memorandum of Law Submitted Form

IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI , AND , BY AND THROUGH PLAINTIFFS HER MOTHER AND NEXT FRIEND, VS. NO. , AND DEFENDANTS INSTRUCTION NO. The Court instructs the jury that the Plaintiffs, , and , ha d a duty to exercise reasonable care for their own safety at the tine of the accident. As used i n this instruction, the phrase "reasonable care" means that standard of care by which an ordinary, reasonable person would use under similar circumstances as the circumstances existing at the time of the accident. If you find that any of the Plaintiffs failed at the ti me of the accident to exercise such reasonable care, and if you further find that such failure, if any, was the sol e and proximate cause of the accident and any resulting injuries, then your verdict must be for the Defendants, , and . If you find any such failure to exercise reasonable care on the part of Plaintiffs, , and , and if you further find such failure , if any, was a proximate contributing cause of the accident and any resulting injuries, then even if you return a verdict for any of the Plaintiffs, a verdict for any of the Plaintiffs under these circumstanc es must be reduced in proportion to such proximate contributing negligence, if any, so found on the part of each Plaintiff. You should separately consider the claims of each Plaintiff and e ach Plaintiff's conduct in determining whether, under this instruction, you find for each Plaintiff and the ext ent of each Plaintiff's contributing negligence, if any. The standard of care applicable to , a minor, for purposes of this instruction is that standard of care which an ordinary, reasonable person of like age and experience would use under similar circumstances as the circumstances existed at the time of the accident.