CACI No. 2600

[Name of plaintiff] claims that [name of defendant] [refused to grant [him/

her/nonbinary pronoun] [family care/medical] leave] [refused to return

[him/her/nonbinary pronoun] to the same or a comparable job when [his/

her/nonbinary pronoun] [family care/medical] leave ended] [other violation

of CFRA rights]. To establish this claim, [name of plaintiff] must prove all

of the following:

1. That [name of plaintiff] was eligible for [family care/medical]

leave;

2. That [name of plaintiff] [requested/took] leave [insert one of the

following:]

2. [for the birth of [name of plaintiff]’s child or bonding with the

child;]

2. [for the placement of a child with [name of plaintiff] for adoption

or foster care;]

2. [to care for [name of plaintiff]’s [child/parent/spouse/domestic

partner/grandparent/grandchild/sibling] who had a serious health

condition;]

2. [to care for an individual designated by [name of plaintiff] [who is

a blood relative/whose association to [name of plaintiff] is

equivalent to a family relationship] who had a serious health

condition;]

2. [for [name of plaintiff]’s own serious health condition that made

[him/her/nonbinary pronoun] unable to perform the functions of

[his/her/nonbinary pronoun] job with [name of defendant];]

2. [for [specify qualifying military exigency related to covered active

duty or call to covered active duty of a spouse, domestic partner,

child, or parent, e.g., [name of plaintiff]’s spouse’s upcoming military

deployment on short notice];]

3. That [name of plaintiff] provided reasonable notice to [name of

defendant] of [his/her/ nonbinary pronoun] need for [family care/

medical] leave, including its expected timing and length. [If [name

of defendant] notified [his/her/ nonbinary pronoun /its] employees

that 30 days’ advance notice was required before the leave was to

begin, then [name of plaintiff] must show that [he/she/ nonbinary

pronoun] gave that notice or, if 30 days’ notice was not reasonably

possible under the circumstances, that [he/she/ nonbinary pronoun]

gave notice as soon as possible];

4. That [name of defendant] [refused to grant [name of plaintiff]’s

request for [family care/medical] leave/refused to return [name of

plaintiff] to the same or a comparable job when [his/her/ nonbinary

pronoun] [family care/medical] leave ended/ other violation of CFRA

rights];

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

6. That [name of defendant]’s [decision/conduct] was a substantial

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

New September 2003; Revised October 2008, May 2021, May 2023