CACI No. 2502

§ 12940(a))

[Name of plaintiff] claims that [name of defendant] had [an employment

practice/a selection policy] that wrongfully discriminated against [him/

her/nonbinary pronoun]. To establish this claim, [name of plaintiff] must

prove all of the following:

1. That [name of defendant] was [an employer/[other covered entity]];

2. That [name of plaintiff] [was an employee of [name of defendant]/

applied to [name of defendant] for a job/[other covered relationship

to defendant]];

3. That [name of defendant] had [an employment practice of [describe

practice]/a selection policy of [describe policy]] that had a

disproportionate adverse effect on [describe protected group];

4. That [name of plaintiff] is [describe protected characteristic or

combination of characteristics];

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

6. That [name of defendant]’s [employment practice/selection policy]

was a substantial factor in causing [name of plaintiff]’s harm.

New September 2003; Revised June 2011, May 2024*, December 2025