[Name of plaintiff] claims that [name
of defendant] was negligent because [ he/she] did
not warn [ name of plaintiff] or a law enforcement
agency about [name of third party ]'s threat of violent
behavior. To establish this claim, [name of plaintiff]
must prove all of the following: 1. That [name of
defendant] was a psychotherapist; 2. That [name of
third party] was [name of defendant ]'s patient; 3.
That [name of third party] communicated a serious
threat of physical violence to [name of defendant];4.
That [name of defendant] knew or should have known
that [name of plaintiff] was [name of third party
]'s intended victim; and 5. That [name of defendant]
did not make reasonable efforts to warn [name of plaintiff]
and a law enforcement agency about the threat.
(DocID: 168)