CACI No. 3109

§ 15610.06)

[Name of plaintiff] claims that [[name of individual defendant]/ [and] [name

of employer defendant]] abducted [him/her/ nonbinary pronoun/[name of

decedent]] 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] [removed [name of plaintiff/decedent] from California

and] restrained [him/her/ nonbinary pronoun /[name of decedent]]

from returning to California;

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] did not have the capacity to

consent to the [removal and] restraint;]

3. [or]

3. [That [[name of plaintiff/decedent]’s conservator/the court] did not

consent to the [removal and] restraint;]

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

5. 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