401.20b Issues on Plaintiff's Claim - Premises Liability - Landowner or Possessor's Negligence (Toward Discovered Trespasser or Foreseeable Licensee) The [next] issues on (claimant)'s claim, for you to decide are whether (defendant) negligently failed to warn (claimant) of a dangerous condition and risk which were known to (defendant) and of which (claimant) neither knew nor should have known, by the use of reasonable care; and, if so, whether such negligence was a legal cause of [loss] [injury] [or] [damage] to (claimant, decedent or person for whose injury claim is made).