3901. Introduction to Tort Damages Liability Established

3901. Introduction to Tort Damages--Liability Established Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 If you decide that [name of plaintiff] was harmed and that [name of defendant]'s [insert description of cause of action, e.g., "negligence"] was a substantial factor in causing the harm, you also must decide how much money will reasonably compensate [name of plaintiff] for the harm. This compensation is called "damages." The amount of damages must include an award for each item of harm that was caused by [name of defendant]'s wrongful conduct, even if the particular harm could not have been anticipated. [Name of plaintiff] does not have to prove the exact amount of damages that will provide reasonable compensation for the harm. However, you must not speculate or guess in awarding damages. [The following are the specific items of damages claimed by [name of plaintiff]:] [Insert applicable instructions on items of damage.] ________________________________________________________________________________ New September 2003; Revised October 2004, June 2005