UJI 13-1647. Negligence in [hiring] [supervising] [retaining] an employee.1

To establish the claim of negligence in [hiring] [supervising] [retaining] an employee, ____________________ (name of the plaintiff) has the burden of proving the following: 1. _____________________ (Name of the defendant) was the employer of ____________________ (name of the employee); 2. _____________________ (Name of the defendant) knew or should have known that [hiring] [retaining] [supervising] [______________________ (insert other employer conduct)2] ____________________ (name of the employee) would create an unreasonable risk of injury to [a group or class that includes the plaintiff] [__________________ (insert name of the plaintiff)]; 3. ____________________ (Name of the defendant) failed to use ordinary care in [hiring] [retaining] [supervising][_________________________ (insert other employer conduct)2] ________________________ (name of employee); 4. __________________ (Name of the defendant)’s negligence in [hiring] [retaining] [supervising] [__________________________ (insert other employer conduct)2] was a cause of ____________________ (name of the plaintiff)’s injury.