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“Defendant claims that Plaintiff’s future [economic] damages for [loss of earnings/future medical expenses/lost profits], if any, should be reduced to present cash value. This is because money received now will, through investment, grow to a larger amount in the future. Present cash value is the amount of money that, if reasonably invested today, will provide Plaintiff with the amount of his future damages. [Defendant must prove, through expert testimony, the present cash value of Plaintiff’s future [economic] damages. It is up to you to decide the present cash value of Plaintiff’s future [economic] damages in light of all the evidence presented by the parties.] [If you decide that Plaintiff’s harm includes future [economic] damages for [loss of earnings/future medical expenses/lost profits], then you must reduce the amount of those future damages to their present cash value. You must [use the interest rate of percent []] as agreed to by the parties in determining the present cash value of future [economic] damages.]”

[CACI Jury Instructions [citations omitted]]

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Law Offices of James R. Dickinson – 909-848-8448

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