[The failure of______________ <insert name of decedent> or another

person to use reasonable care may have contributed to the death. But if the defendant’s act was a substantial factor causing the death, then the defendant is legally responsible for the death even though______________________ <insert name of decedent> or another person
may have failed to use reasonable care.]

[The failure of the (doctor(s)/ [or] medical staff) to use reasonable care in treating       <insert name of decedent> may have
contributed to the death. But if the injury inflicted by the defendant was a substantial factor causing the death, then the defendant is legally responsible for the death even though the (doctor[s]/ [or] medical staff) may have failed to use reasonable care. On the other hand, if the injury inflicted by the defendant was not a substantial factor causing the death, but the death was caused by grossly improper treatment by the (doctor[s]/[or] medical staff), then the defendant is not legally responsible for the death.]

[_____________ <insert name of decedent> may have suffered from

an illness or physical condition that made (him/her) more likely to die from the injury than the average person. The fact that
___________ <insert name of decedent> may have been more
physically vulnerable is not a defense to (murder/ [or] manslaughter). If the defendant’s act was a substantial factor causing the death, then the defendant is legally responsible for the

death. This is true even if_____________ <insert name of decedent>
would have died in a short time as a result of other causes or if