“To recover damages for the loss of the ability to earn money as a result of the injury, Plaintiff must prove: 1. That it is reasonably certain that the injury that Plaintiff sustained will cause him to earn less money in the future than he otherwise could have earned; and 2. The reasonable value of that loss to him. In determining the reasonable value of the loss, compare what it is reasonably probable that Plaintiff could have earned without the injury to what he can still earn with the injury. [Consider the career choices that Plaintiff would have had a reasonable probability of achieving.] It is not necessary that he have a work history.”
[CACI Jury Instructions [citations omitted]]
