“Plaintiff claims that Defendant made a false representation that harmed him. To establish this claim, Plaintiff must prove all of the following: 1. That Defendant represented to Plaintiff that a fact was true; 2. That Defendant’s representation was false; 3. That Defendant knew that the representation was false when she made it, or that she made the representation recklessly and without regard for its truth; 4. That Defendant intended that Plaintiff rely on the representation; 5. That Plaintiff reasonably relied on Defendant’s representation; 6. That Plaintiff was harmed; and 7. That Plaintiff’s reliance on Defendant’s representation was a substantial factor in causing his harm.”
[CACI Jury Instructions [citations omitted]]
