CACI No. 4111

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

because [name of defendant] misled [him/her/ nonbinary pronoun] by failing

to provide [name of plaintiff] with complete and accurate information. To

establish this claim, [name of plaintiff] must prove all of the following:

1. That [name of defendant] was [name of plaintiff]’s

[agent/stockbroker/real estate agent/real estate broker/corporate

officer/partner/[insert other fiduciary relationship]];

2. That [name of defendant] acted on [name of plaintiff]’s behalf for

purposes of [insert description of transaction, e.g., purchasing a

residential property];

3. That [name of defendant] knew, or should have known, that

[specify information at issue];

4. That [name of defendant] misled [name of plaintiff] by [failing to

disclose this information/providing [name of plaintiff] with

information that was inaccurate or incomplete];

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

6. That [name of defendant]’s conduct was a substantial factor in

causing [name of plaintiff]’s harm.

New November 2017; Revised May 2020