Va. Model Jury Instr. Civ. No. 40.250

You shall find your verdict for the plaintiff if he proved by the greater weight of the evidence:

(1) that there was a [contract expectancy; prospective business relationship; economic advantage;

contract] between the plaintiff and (name of third party); and

(2) that the defendant knew of this [contract expectancy; prospective business relationship; economic

advantage; contract]; and

(3) that the defendant used improper methods to interfere with the [contract expectancy;

prospective business relationship; economic advantage; contract]; and

(4) that the defendant intended to interfere with the [contract expectancy; prospective business

relationship; economic advantage; contract]; and

(5) that it was reasonably certain that [the business relationship would have continued; the

expectancy would have been realized; the economic advantage would have been realized; the contract

would have continued] in the absence of the defendant’s conduct; and

(6) that the plaintiff was damaged by the disruption of the [contract expectancy; prospective business

relationship; economic advantage; contract].

You shall find your verdict for the defendant if the plaintiff failed to prove any one or more of

these elements; or if you find that the defendant proved by the greater weight of the evidence

that the interference was justified, privileged or not improper.