21.08 [1995 Revision] Verdict Directing-Actions Against Health Care Providers-Lost Chance of Survival-No Comparative Fault-Multiple Negligent Acts

Instruction No 1 21.08 [1995 Revision] Verdict Directing--Actions Against Health Care Providers--Lost Chance of Survival--No Comparative Fault--Multiple Negligent Acts Your verdict must be for plaintiff (state name of plaintiff ad litem or personal representative ), if you believe: First, defendant (state the name ) either: (here set out act or omission complained of ), or (here set out alternative act or omission complained of ), and Second, (state name of decedent ) then had a material chance of [survival] [recovery], and Third, defendant, in any one or more of the respects submitted in paragraph First, was thereby negligent, and Fourth, as a direct result of such negligence, (state name of decedent) lost [all] [or] [a material part of] such chance of [survival] [recovery]. * Number [unless you believe plaintiff is not entitled to recover by reason of Instruction (here insert number of affirmative defense instruction ) ].