“Plaintiff claims he was harmed because Defendant negligently misrepresented a fact. 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 not true; 3. That [although Defendant may have honestly believed that the representation was true, Defendant had no reasonable grounds for believing the representation was true when he made it; 4. That Defendant intended that Plaintiff rely on
this 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]]
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