414.5 Issues on Claim The issues you must decide on (claimant)'s claim against (defendant) are whether: 1. (Defendant) deliberately intended to injure (claimant), or 2. whether (defendant) (a) engaged in conduct that (defendant) knew, based upon [prior similar accidents] [or] [explicit warnings specifically identifying a known danger], was virtually certain to result in death or injury to (claimant); and (claimant) was not aware of the risk because the danger was not apparent; and (defendant) deliberately concealed or misrepresented the danger so as to prevent (claimant) from exercising an informed judgment; (b) (c) and, if so, whether that conduct was a legal cause of [loss] [injury] [or] [damage] to (claimant).