“Plaintiff claims that he was harmed by an unsafe condition while employed by Plaintiff’s employer and working on Defendant’s property. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant owned/leased/occupied/controlled the property; 2. That Defendant negligently provided unsafe equipment
that contributed to Plaintiff’s injuries; 3. That Plaintiff was harmed; and 4. That Defendant’s conduct was a substantial factor in causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]
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