UJI 13-843A. Special or consequential damages.

In addition to direct damages, ____________________ (name of party asserting breach) also seeks to recover damages for ____________________ (describe damages alleged to have happened as the result of special circumstances, beyond the ordinary course of events, that the breaching party had reason to know). To recover for these alleged damages, _______________ (name of party asserting breach) must prove the following: 1. When the contract was made, ______________ (name of opposing party) had reason to know that these damages would probably result from ______________’s (name of opposing party) breach; 2. These damages were in fact caused by __________________ (name of opposing party)’s breach of contract; and 3. The amount of damages.