409.8 Issues on Plaintiff's Claim - Negligent Misrepresentation The [next] issues for you to decide on (claimant)'s claim [for negligent misrepresentation and they*] are: First, whether (defendant) made a statement concerning a material fact that [he] [she] [it] believed to be true but which was in fact false; Second, whether (defendant) was negligent in making the statement because [he] [she] [it] should have known the statement was false; Third, whether in making the statement, (defendant) intended [or expected] that another would rely on the statement; and Fourth, whether (claimant) justifiably relied on the false statement. * The bracketed language should be used for clarity when there are also claims for fraudulent misrepresentations and/or negligently supplying false information for the guidance of others.