“Plaintiff is not entitled to recover damages for economic losses that Defendant proves Plaintiff could have avoided by returning to gainful employment as soon as it was reasonable for him to do so. To calculate the amount of damages you must: 1. Determine the amount Plaintiff would have earned from the job he held at the time he was injured; and 2. Subtract the amount Plaintiff earned or could have earned by returning to gainful employment. The resulting amount is Plaintiff’s damages for past lost earnings.”
[CACI Jury Instructions [citations omitted]]
