“Plaintiff claims that he was harmed by Defendant’s negligent failure to obtain insurance requested by him. To establish this claim, Plaintiff must prove all of the following: 1. That Plaintiff requested Defendant to obtain [requested insurance] and Defendant promised to obtain that insurance for him; 2. That Defendant was negligent in failing to obtain the promised insurance; 3. That Plaintiff was harmed; and 4. That Defendant’s negligence was a substantial factor in causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]
