“The cost of future medical monitoring. To recover damages for this item, Plaintiff must prove both of the following: 1. That as a result of the toxic exposure, the need for future monitoring is reasonably certain; and 2. That the monitoring is reasonable. In deciding these issues, you should consider the following: (a) The significance and extent of Plaintiff’s exposure to the chemical(s); (b) The toxicity of the chemical(s); (c) The relative increase in Plaintiff’s chance of getting the disease as a result of the exposure, when compared to: (i) his chances of developing the disease had he not been exposed, and (ii) the chances that members of the public at large will develop the disease; (d) The seriousness of the disease that may result from the exposure; and (e) The medical benefit of early detection and diagnosis. [Defendant is not required to pay for medical monitoring that is required for reasons other than Plaintiff’s exposure to toxic chemicals.] [Defendant is only required to pay for additional or different monitoring that is required because of the toxic exposure.]”
[CACI Jury Instructions [citations omitted]]
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