21.01 [1988 Revision] Verdict Directing-Actions Against Health Care Providers-No Comparative Fault

Instruction No 1 21.01 [1988 Revision] Verdict Directing--Actions Against Health Care Providers--No Comparative Fault Your verdict must be for the plaintiff if you believe: First, defendant (here set out act or omission complained of; e.g., "failed to set plaintiff's broken leg bones in natural alignment," or "left a sponge in plaintiff's chest after performing an operation," or "failed to administer tetanus antitoxin "), and Second, defendant was thereby negligent, and Third, as a direct result of such negligence plaintiff sustained damage. * [unless you believe plaintiff is not entitled to recover by reason of Instruction Number (here insert number of affirmative defense instruction ) ].