“Plaintiff claims that Defendant breached an agreement to pay life insurance benefits. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant or its authorized agent received Decedent’s application for life insurance; 2. That Decedent paid the first insurance premium; 3. That Decedent died [on/after/before] [relevant date]; and 4. The amount of the insurance benefits that Defendant failed to pay.”
[CACI Jury Instructions [citations omitted]]
