UJI 13-815. Promissory estoppel; definition.

________________________ (name of the plaintiff) [also] seeks damages based upon a claim of promissory estoppel. To establish this claim, ______________________ (name of the plaintiff) must prove all of the following: 1. that _________________ (name of the defendant) made a promise to ____________________ (name of the plaintiff); 2. that _________________ (name of the plaintiff) relied on the promise and it was reasonable for ____________ (name of the plaintiff) to do so; 3. that the promise caused ___________________ (name of the plaintiff) to change ____________(name of plaintiff’s) position by ______________________ (insert action or forbearance of the plaintiff); 4. that the change in position was substantial; 5. that ______________________ (name of the defendant) knew or should have known that ________________________ (name of the plaintiff) would ___________________ (insert action or forbearance) after __________________ (name of the defendant) made the promise.