700.07. Performance by Plaintiff
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700.07 Performance by Plaintiff As stated in Instruction 1, the second element of a contract claim [name of plaintiff] must prove is [he] [she] [it] [performed all obligation[s]] [condition[s]] [the occurrence of a condition] required of [him] [her] [it] under the contract. To recover on [his] [hers] [its] claim, [name of plaintiff] must prove [he] [she] [it] did what the contract required [him] [her] [it] to do or [had a valid excuse for not doing so], as follows: [State what the plaintiff claims he/she performed under the contract or state the valid excuse for not performing.] You will address this issue in question [__] on your verdict.