3934. Damages on Multiple Legal Theories Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 [Name of plaintiff] seeks damages from [name of defendant] under more than one legal theory. However, each item of damages may be awarded only once, regardless of the number of legal theories alleged. You will be asked to decide whether [name of defendant] is liable to [name of plaintiff] under the following legal theories [list]: 1. 2. 3. [e.g., breach of employment contract]; [e.g., wrongful termination in violation of public policy]; [continue]. The following items of damages are recoverable only once under all of the above legal theories: 1. 2. 3. [e.g., lost past income]; [e.g., medical expenses]; [continue]. [The following additional items of damages are recoverable only once for [specify legal theories]: 1. 2. [e.g., emotional distress]; [continue]. [Continue until all items of damages recoverable under any legal theory have 3934. Damages on Multiple Legal Theories Instruction No 1 Request by Plaintiff Given as Proposed Refused Withdrawn Request by Defendant Given as Modified Requested by Given on Court's Motion Judge Instruction No 1 been listed.]] ________________________________________________________________________________ New December 2010