To establish a claim for negligence, [Plaintiff] must prove by the greater weight of the evidence:

1) The standard of care applicable to [Defendant] at the time of the incident in question;

2) Failure to meet that standard by [Defendant];

3) [Plaintiff] was damaged; and

4) The failure to meet that standard of care proximately caused [the Plaintiff's] damages.

[Evidence as to the standard of care, the failure to meet that standard of care, and proximate cause must be established by expert testimony.]

* * * * *