“Plaintiff claims that Defendant failed to perform the work for the [e.g., kitchen remodeling]. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant failed to perform his work competently or provide the proper materials by [e.g., failing to apply sufficient coats of paint or failing to complete the project in substantial conformity with
the plans and specifications]; and 2. That Plaintiff was harmed by Defendant’s failure.”
[CACI Jury Instructions [citations omitted]]
