UJI 13-304. Burden of proof; greater weight of the evidence; clear and convincing evidence.

A party seeking a recovery [or a party relying upon a defense] has the burden of proving every essential element of the claim [or defense] by the greater weight of the evidence. To prove by the greater weight of the evidence means to establish that something is more likely true than not true. [When I say, in these instructions, that the party has the burden of proof on _________________________ (theory(ies) of recovery by name), I mean that you must be persuaded that what is sought to be proved is more probably true than not true. Evenly balanced evidence is not sufficient.] On _______________________ (fraud, etc.), however, a higher degree of proof is required. Plaintiff has the burden of proving __________________ by clear and convincing evidence.]