“Plaintiff claims that he was harmed because Defendant misled him by failing to provide Plaintiff with complete and accurate information. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant was Plaintiff’s
[agent/stockbroker/real estate agent/real estate broker/corporate officer/partner]; 2. That Defendant acted on Plaintiff’s behalf for purposes of [e.g., purchasing a residential property]; 3. That Defendant knew, or should have known, that []; 4. That Defendant misled Plaintiff by [failing to disclose this information/providing Plaintiff with information that was inaccurate or incomplete]; 5. That Plaintiff was harmed; and 6. That Defendant’s conduct was a substantial factor in
causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]
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