[Name of defendant] claims that [name of public employee] was not
required to comply with Vehicle Code section [insert section
number] because [he/she] was operating an authorized emergency
vehicle and was responding to an emergency at the time of the
accident.
To establish that [name of public employee] was not required to
comply with section [insert section number], [name of defendant]
must prove all of the following:
1. That [name of public employee] was operating an authorized
emergency vehicle;
2. That [name of public employee] was responding to an
emergency situation at the time of the accident; and
3. That [name of public employee] sounded a siren when
reasonably necessary and displayed front red warning
lights.
If you decide that [name of defendant] proved all of these things,
then you cannot find it negligent for a violation of section [insert
section number]. However, even if you decide that [name of
defendant] proved all of these things, you may find it negligent if
[name of public employee] failed to operate [his/her] vehicle with
reasonable care, taking into account the emergency situation.
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