CACI No. 3106

Code, § 15610.63)

[Name of plaintiff] claims that [he/she/ nonbinary pronoun/[name of

decedent]] was physically abused by [[name of individual defendant]/ [and]

[name of employer defendant]] in violation of the Elder Abuse and

Dependent Adult Civil Protection Act. To establish this claim, [name of

plaintiff] must prove all of the following:

1. That [[name of individual defendant]/[name of employer defendant]’s

employee] physically abused [name of plaintiff/decedent] by [insert

applicable grounds for abuse];

2. That [name of plaintiff/decedent] was [65 years of age or older/a

dependent adult] at the time of the conduct;

3. That [name of plaintiff/decedent] was harmed; and

4. That [[name of individual defendant]’s/[name of employer

defendant]’s employee’s] conduct was a substantial factor in

causing [name of plaintiff/decedent]’s harm.

New September 2003; Revised December 2005, October 2008