“Defendant claims that Plaintiff’s own negligence contributed to his harm. To succeed on this claim, Defendant must prove both of the following: 1. That Plaintiff was negligent; and 2. That Plaintiff’s negligence was a substantial factor in
causing his harm. If Defendant proves the above, Plaintiff’s damages are reduced by your determination of the percentage of Plaintiff’s responsibility. I will calculate the actual reduction.”
[CACI Jury Instructions [citations omitted]]
