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1200 California Street, Suite 260, Redlands, CA 92374

“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]]

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Law Offices of James R. Dickinson – 909-848-8448

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