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Contract Damages – UCC: Buyer's Breach by Nonpayment. After Acceptance – Seller's Action for Price. 24. 21. Definition of Proximate Cause. Guide for Using the Proposed Plain Language Model Jury Instructions: 707 Contracts - Breach of Contract - General Instruction and Verdict Form. MODEL JURY INSTRUCTIONS IS AVAILABLE FOR PURCHASE FROM Was the plaintiff damaged by the [breach; termination] of the contract? 451 Fiduciary Duty (Shared Instructions with Civil Jury Instructions) Section 500 – Damages 416.4 Breach of Contract – Essential Factual Elements The parties dispute whether [defendant/plaintiff] did what the contract required of [him][her][it]. · [A “material breach” is a failure to perform an essential CONTRACTS. CONTRACTS. INTRODUCTION. These instructions deal with a cause of action for breach of contract when the plaintiff is seeking money damages. WPI 300.02 (7th ed.) Washington Practice Series TM. Washington Pattern Jury Instructions--Civil. July 2019 Update. Washington State Supreme Court Committee on 22.24 Damages - Breach of Contract - General. 22.27 Punitive Damages. 22.27A Punitive Damages May Be Recovered Against Tortfeasor's Estate.Hawai?i Civil Jury Instructions. DEFENSE. INSTRUCTION NO. 16.12: BREACH OF IMPLIED EMPLOYMENT CONTRACT: ELEMENTS. INSTRUCTION NO.