1511. Wrongful Use of Civil Proceedings227Affirmative Defense227Attorney222s Reliance on Information Provided by Client Instruction No 1 Request by Plaintiff Request by Defendant Requested by Given as Proposed Given as Modified Given on Court222s Motion Refused Withdrawn Judge Instruction No 1 When filing a lawsuit for a client, an attorney is entitled to rely on the facts and information provided by the client. [Name of attorney defendant] claims that [he/she] had reasonable grounds for bringing the lawsuit because [he/she] was relying on facts and information provided by [his/her] client. To succeed on this defense, [name of attorney defendant] must prove all of the following: 1. That [name of client] provided [name of attorney defendant] with the following information: [specify information on which attorney relied]; 2. That [name of attorney defendant] did not know that this information was false or inaccurate; and 3. That [name of attorney defendant] relied on the facts and information provided by the client.