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  • Writer's pictureLandon Stinson

401.19 ISSUES ON PLAINTIFF’S CLAIM — COMMON CARRIER (Florida Standard Jury Instruction)

401.19 ISSUES ON PLAINTIFF’S CLAIM — COMMON CARRIER


The [next] issues on (claimant’s) claim, for you to decide are: whether (defendant) in (describe conduct) failed to exercise the highest degree of care for the safety of (claimant); and, if so, whether that failure was a legal cause of the [loss] [injury] [or] [damage] to (claimant, decedent, or person for whose injury claim is made).


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