California Wrongful Death Case - Discovery; Depositions

1. The value of the financial support, if any, that [name of minor] would have contributed to the family during either the life expectancy that [name of minor] had before [his/her] death or the life expectancy of [name of plaintiff], whichever is shorter;

2. The loss of gifts or benefits that [name of plaintiff] could have expected to receive from [name of minor];

3. Funeral and burial expenses; and

4. The reasonable value of household services that [name of minor] would have provided.

Your award of any future economic damages must be reduced to present cash value.

[Name of plaintiff] also claims the following noneconomic damages: The loss of [name of minor]'s love, companionship, comfort, care, assistance, protection, affection, society, and moral support.

No fixed standard exists for deciding the amount of noneconomic damages. You must use your judgment to decide a reasonable amount based on the evidence and your common sense. [For noneconomic damages, determine the amount in current dollars paid at the time of judgment that will compensate [name of plaintiff] for those damages, and do not reduce them further to present cash value.]

Do not include in your award any compensation for the following:
1. [Name of plaintiff]'s grief, sorrow, or mental anguish; or

2. [Name of minor]'s pain and suffering.

In computing these damages, you should deduct the present cash value of the probable costs of [name of minor]'s support and education.

In deciding a person's life expectancy, consider, among other factors, that person's health, habits, activities, lifestyle, and occupation. Life expectancy tables are evidence of a person's life expectancy but are not conclusive.

[In computing these damages, consider the losses suffered by all plaintiffs and return a verdict of a single amount for all plaintiffs. I will divide the amount [among/between] the plaintiffs.]