CACI No. 1902

[Name of plaintiff] claims [he/she/ nonbinary pronoun] was harmed because

[name of defendant] made a false promise. To establish this claim, [name

of plaintiff] must prove all of the following:

1. That [name of defendant] made a promise to [name of plaintiff];

2. That [name of defendant] did not intend to perform this promise

when [he/she/ nonbinary pronoun] made it;

3. That [name of defendant] intended that [name of plaintiff] rely on

this promise;

4. That [name of plaintiff] reasonably relied on [name of defendant]’s

promise;

5. That [name of defendant] did not perform the promised act;

6. That [name of plaintiff] was harmed; and

7. That [name of plaintiff]’s reliance on [name of defendant]’s promise

was a substantial factor in causing [his/her/ nonbinary pronoun /its]

harm.

New September 2003; Revised December 2012, December 2013