“If you decide Defendant is responsible for the original harm, Plaintiff is not entitled to recover damages for harm that Defendant proves Plaintiff could have avoided with reasonable efforts or expenditures. You should consider the reasonableness of Plaintiff’s efforts in light of the circumstances facing him at the time, including his ability to make the efforts or expenditures without undue risk or hardship. If Plaintiff made reasonable efforts to avoid harm, then your award should include reasonable amounts that he spent for this purpose.”
[CACI Jury Instructions [citations omitted]]
