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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

section serves

Citation
section serves
Parent Document
Patrick Blanks v. Fluor Corporation (2014)
Jurisdiction
Missouri (state)
Effective Date
2014-06-17

Other Sections in This Document (3438)

Full Text

1,443 chars
47
     The “partner” verdict director for Fluor reads:
                    On the claim of plaintiff (--) for compensatory damages for personal injury
           against defendant Fluor Corporation, your verdict must be for plaintiff (---) if you
           believe:
                    First, defendant Fluor Corporation was a partner of the Doe Run Company
           Partnership, and
                    Second, while defendant Fluor Corporation was a partner of the Doe Run
           Company Partnership, the adjacent community of Herculaneum was contaminated with
           unsafe levels of lead which originated from the smelter operations, and
                    Third, at that time, defendant Fluor Corporation had information from which it,
           in the exercise of ordinary care, knew or should have known that the adjacent community
           of Herculaneum was contaminated with unsafe levels of lead which originated from the
           smelter operations, and
                    Fourth, defendant Fluor Corporation allowed plaintiff (---), a resident of
           Herculaneum, to be exposed to unsafe levels of lead which originated from the smelter
           operations before May 26, 1990, and
                    Fifth, defendant Fluor Corporation was thereby negligent, and
                    Sixth, such negligence directly caused or directly contributed to cause damage to plaintiff
                    (---).