CACI No. 2710

Factual Elements (Lab. Code, § 970)

[Name of plaintiff] claims that [name of defendant] made [a] false

representation[s] about work to persuade [him/her/ nonbinary pronoun] to

change [his/her/ nonbinary pronoun] residence. To establish this claim,

[name of plaintiff] must prove all of the following:

1. That [name of defendant] made [a] representation[s] to [name of

plaintiff] about [insert one or more of the following :]

1. [the kind, character, or existence of work;]

1. [the length of time work would last;]

1. [the compensation for work;]

1. [the sanitary or housing conditions relating to work;]

1. [the existence or nonexistence of any pending strike, lockout, or

other labor dispute affecting work;]

2. That [name of defendant]’s representation(s) [was/were] not true;

3. That [name of defendant] knew when the representation[s] [was/

were] made that [it/they] [was/were] not true;

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

the representation[s];

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

representation[s] and changed [his/her/ nonbinary pronoun]

residence for the purpose of working for [name of defendant];

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

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

representation(s) was a substantial factor in causing

[his/her/nonbinary pronoun] harm.

New September 2003