359. Present Cash Value of Future Damages Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 To recover for future harm, [name of plaintiff] must prove that the harm is reasonably certain to occur and must prove the amount of those future damages. The amount of damages for future harm must be reduced to present cash value. This is necessary because money received now will, through investment, grow to a larger amount in the future. [Name of defendant] must prove the amount by which future damages should be reduced to present value. To find present cash value, you must determine the amount of money that, if reasonably invested today, will provide [name of plaintiff] with the amount of [his/her/its] future damages. [You may consider expert testimony in determining the present cash value of future damages.] [You must use [the interest rate of percent/ [and] [specify other stipulated information]] agreed to by the parties in determining the present cash value of future damages.] ___________________________________________________________________________ New September 2003; Revised December 2010, June 2013