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Analytic Rehabilitation

California Civil Jury Instructions

a/k/a
"California Civil Instructions" or CACI

JURY INSTRUCTION 3903A
MEDICAL EXPENSES - PAST AND FUTURE

To recover damages for past medical expenses, [name of plaintiff] must prove the reasonable cost of reasonably necessary medical care that [he/she] has received.

To recover damages for future medical expenses, [name of plaintiff] must prove the reasonable cost of reasonably necessary medical care that [he/she] is reasonably certain to need in the future.

JURY INSTRUCTION 3903C
PAST AND FUTURE LOST EARNINGS

To recover damages for past lost earnings, [name of plaintiff] must prove the amount of [insert one or more of the following: income/earnings/salary/wages] that [he/she] has lost to date.

To recover damages for future lost earnings, [name of plaintiff] must prove the amount of [insert one or more of the following: income/earnings/salary/wages] [he/she] will be reasonably certain to lose in the future as a result of the injury.

JURY INSTRUCTION 3903D
LOST EARNING CAPACITY

To recover damages for the loss of the ability to earn money, [name of plaintiff] must prove the amount of money [he/she] would have been reasonably certain to earn if the injury had not occurred. It is not necessary that [he/she] have a work history.

A full text version of the CACI can be found at the California Courts web site.