“Plaintiff claims that Defendant must pay all [or part of] a judgment against Insured. To establish this claim, Plaintiff must prove all of the following: 1. That Plaintiff brought a lawsuit for personal injury/wrongful death/property damage against Insured and a judgment was entered against Insured; 2. That all [or part of] Insured’s liability under the
judgment is covered by an insurance policy with Defendant; and 3. The amount of the judgment [covered by the policy].”
[CACI Jury Instructions [citations omitted]]
