Civil: Jury Instruction, Past and Future Lost Earnings (Economic Damage)
“To recover damages for past lost earnings, Plaintiff must prove the amount of: income/earnings/salary/wages that…
Civil: Jury Instruction, Medical Monitoring—Toxic Exposure (Economic Damage)
“The cost of future medical monitoring. To recover damages for this item, Plaintiff must prove…
Civil: Jury Instruction, Past and Future (Economic Damage)
“To recover damages for past medical expenses, Plaintiff must prove the reasonable cost of reasonably…
Civil: Jury Instruction, Economic and Noneconomic Damages
“The damages claimed by Plaintiff for the harm caused by Defendant fall into two categories…
Civil: Jury Instruction, Tort Damages—Liability Established
“If you decide that Plaintiff was harmed and that Defendant’s [e.g., “negligence”] was a substantial…
Civil: Jury Instruction, Tort Damages—Liability Contested
“If you decide that Plaintiff has proven his claim against Defendant, you also must decide…
Civil: Jury Instruction, Implied Contractual Indemnity
“Indemnitee claims that she is/was/may be required to pay [e.g., “a court judgment in favor…
Civil: Jury Instruction, Comparative Fault Between and Among Tortfeasors
“Indemnitee claims that he is/was required to pay [e.g., “a court judgment in favor of…
Civil: Jury Instruction, Going-and-Coming Rule—Compensated Travel Time Exception
“If an employer has agreed to compensate an employee for the employee’s commuting time, then…
Civil: Jury Instruction, Going-and-Coming Rule—Business-Errand Exception
“In general, an employee is not acting within the scope of employment while traveling to…