“Plaintiff claims that Defendant failed to disclose certain information, and that because of this failure to disclose, Plaintiff was harmed. In order to establish this claim, Plaintiff must prove all of the following: 1. That Plaintiff purchased real property from Defendant; 2. That Defendant knew that []; 3. That Defendant did not disclose this information to Plaintiff; 4. That Plaintiff did not know, and could not reasonably have discovered, this information; 5. That Defendant knew that Plaintiff did not know, and could not reasonably have discovered, this information; 6. That this information significantly affected the value or desirability of the property; 7. That Plaintiff was harmed; and 8. That Defendant’s failure to disclose the information was a substantial factor in causing Plaintiff’s harm.”
[CACI Jury Instructions [citations omitted]]