
- Breach of a legally imposed duty of reasonable care owed by the Defendant to the plaintiff;
- Failure to provide a reasonably safe place to work;
- Failure to properly train and supervise plaintiff;
- Failure to take any means or precautions for the safety of defendant’s employees, including plaintiff;
- Creation and maintenance of an unseaworthy vessel;
- Failure to provide minimum safety requirements;
- Failure to provide adequate equipment for the job in question;
- Failure to provide adequate personnel for the job in question;
- Other acts of negligence and unseaworthiness.
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