UJI 13-302B. Statement of factual contentions of plaintiff(s), causation and burden of proof.

To establish _____________________ (theory of recovery by name, e.g., negligence) on the part of [a] defendant(s), the plaintiff(s) [has] [have] the burden of proving [at least one of] [each of] the following: ________________________________ __________________________________________________________________. (NOTE: List by number each claimed act, omission, or condition, etc., referenced to specific defendant(s), which is supported by substantial evidence and that remains at issue.) The plaintiff(s) [has] [have] the burden of proving that such ________________ (theory of recovery by name) was a cause of the [injuries and] damages.