UJI 13-1650. Spoliation of evidence.

_________________ (name of plaintiff) says in this case that ___________________ (name of defendant) intentionally [disposed of, destroyed, mutilated or significantly altered] evidence relevant to a [potential lawsuit] [lawsuit]. In order to prove intentional spoliation of evidence, ___________________ (plaintiff) must prove each of the following: 1. There was [a lawsuit] [the potential for a lawsuit]; 2. ___________________ (defendant) knew there was [a lawsuit] [the potential for a lawsuit]; 3. ___________________ (defendant) disposed of, destroyed, mutilated or significantly altered potential evidence; 4. By defendant’s conduct __________________’s (defendant’s) sole intent was to disrupt or defeat a potential lawsuit; 5. The destruction or alteration of the evidence resulted in __________________’s (plaintiff’s) inability to prove plaintiff’s case; 6. ___________________ (plaintiff) suffered damages as a result of the destruction or alteration.