Fla. Std. Jury Instr. (Civ.) 408.65

[On (claimant’s) claim for civil conspiracy to tortiously interfere with [business relations] [contract terminable at will], you must decide the claim separately for [each defendant] [(list defendants at issue in this claim)].]

The issues on [this claim] [(claimant’s) claim for civil conspiracy to interfere with [business relations] [contract terminable at will] are:

First, [as to] [each defendant] [(list defendants at issue in this claim)] whether [each of them] [(defendant)] entered into an agreement with [another] [others] [each other] to interfere with [business relations] [contract terminable at will] between (claimant) and (person or entity);

Second, whether (defendant) [another] [others] [each other] — in furtherance of the agreement — intentionally interfered with a [contractual relationship] [business relationship] [prospective business relationship] between (claimant) and (person). A person interferes with a [contractual relationship] [business relationship] [prospective business relationship] between two [or more] other persons if [he] [she] [it] induces or otherwise causes one of them to [breach the contract] [terminate the relationship] [not form the relationship]. Therefore, (defendant) [another] [others] [each other] must have known of the existence of the [contractual relationship] [business relationship] [prospective business relationship], and [he] [she] [it] must have either intended to cause the breach of the relationship or acted knowing that [his] [her] [its] actions were likely to cause that result.

(Claimant) does not have to prove that [he] [she] [it] had an enforceable contract with (person or entity), if [he] [she] [it] can prove that (person or entity) would have [complied with] [entered into] the [contractual relationship] [business relationship] [prospective business relationship] if (defendant) [another] [others] [each other] had not improperly interfered;

Third, (defendant) [another] [others] [each other] must have also acted unjustifiably. (Claimant) must prove that (defendant) [another] [others] [each other] acted unjustifiably because defendant [violated a statute] [committed a tort] [or] [committed other improper acts]. A person who interferes with another’s business relations using ordinary business methods of competition does not interfere improperly. But one who uses [physical violence] [misrepresentations] [illegal conduct] [threats of illegal conduct] [or] [(identify other improper conduct)] has no privilege to use those methods, and interference using such methods is improper; and

Fourth, whether the tortious interference was a legal cause of [loss] [or] [damage] to (claimant).

If the greater weight of the evidence does not support (claimant’s) claim, then your verdict should be for (defendant). However, if the greater weight of the evidence supports (claimant’s) claim, [then your verdict should be for (claimant) and against (defendant)] [then you shall consider the defense[s] raised by (defendant)].