PJC Business

D AMAGES

PJC 115.20

PJC 115.20 Question and Instruction on Consequential Damages Caused by Fraud

[Insert predicate, PJC 115.1.]

QUESTION ______ What sum of money, if any, if paid now in cash, would fairly and reasonably compensate Paul Payne for his damages, if any, that were proximately caused by such fraud? [Insert definition of proximate cause, PJC 100.13.] Consider the following elements of damages, if any, and none other. [Insert appropriate instructions. See sample instructions in PJC 115.4 and 115.10 for format, and see PJC 115.5.] In answering questions about damages, answer each question separately. Do not increase or reduce the amount in one answer because of your answer to any other question about damages. Do not speculate about what any party’s ulti mate recovery may or may not be. Any recovery will be determined by the court when it applies the law to your answers at the time of judgment. Do not add any amount for interest on damages, if any. Answer separately in dollars and cents for damages, if any. 1. [ Element A ] sustained in the past. Answer: _______________ 2. [ Element A ] that, in reasonable probability, will be sustained in the future. Answer: _______________ 3. [ Element B ] sustained in the past. Answer: _______________ 4. [ Element B ] that, in reasonable probability, will be sustained in the future. Answer: _______________

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