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24.01 [1992 Revision] Verdict Directing-F.E.L.A.-Failure to Provide Safe Place to Work
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Instruction No 1 24.01 [1992 Revision] Verdict Directing--F.E.L.A.--Failure to Provide Safe Place to Work Your verdict must be for plaintiff if you believe: First, plaintiff was an employee of defendant and a part of his employment in some way closely and substantially affected interstate commerce, and Second, [with respect to such conditions for work,] defendant either failed to provide: reasonably safe conditions for work, or reasonably safe appliances, or reasonably safe methods of work, or reasonably adequate help, and Third, defendant in any one or more of the respects submitted in Paragraph Second was negligent, and Fourth, such negligence resulted in whole or in part in [injury to plaintiff] [the death of (decedent's name) ]. * [unless you believe plaintiff is not entitled to recover by reason of Instruction Number (here insert number of affirmative defense instruction ) ].
