SAMPLE FORMAT FOR AMERICAN RED CROSS (ARC) MEMORANDUM OF ...
(5) The Westfall Act, in contrast, states the sole and exclusive remedy for the negligent acts or omissions of any Federal employees is the FTCA. The Westfall Act applies to personnel outside the United States, United States v. Smith, 499 U.S. 160, 111 Supreme Court 1180 (1991), even when the FTCA itself precludes Government liability. ................
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