MUJI 2d CV2006

Economic damages include past and future lost earnings, including lost benefits, [and lost earning capacity].

Calculate past lost earnings from the date of the harm until the trial. [Calculate future lost earnings from the date of trial forward.]

[Lost earning capacity is not the same as lost earnings. Lost earning capacity means the lost potential to earn income. In determining lost earning capacity, you should consider:

(1) [name of plaintiff]'s actual earnings;

(2) [his] work before and after [describe event];

(3) what [he] was capable of earning had [he] not been injured; and

(4) any other facts that relate to [name of plaintiff]'s employment.]