“Plaintiff claims he was harmed because Defendant made a false promise. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant made a promise to Plaintiff; 2. That Defendant did not intend to perform this promise when she made it; 3. That Defendant intended that Plaintiff rely on this promise; 4. That Plaintiff reasonably relied on Defendant’s promise; 5. That Defendant did not perform the promised act; 6. That Plaintiff was harmed; and 7. That Plaintiff’s reliance on Defendant’s promise was a substantial factor in causing his harm.”
[CACI Jury Instructions [citations omitted]]
