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This instruction is modeled after the third paragraph of COLORADO JURY INSTRUCTIONS. — ... only if a deposition has been admitted as substantive evidence. It ... INSTRUCTION NO. 15. 16. ACTUAL DAMAGES – CLAIM -. Plaintiff has the burden of proving the nature and extent of its damages by a preponderance of the evidence.Plaintiff has the burden of proving his claims, which requires him to prove every essential element of the claims by a preponderance of the evidence. by CB Mueller · 1977 · Cited by 24 — gives him more than any presumption instruction under Rule 301 could give him. That is, the instructions on burden of proof which the judge. Actions Relating to Unincorporated Associations ..................................... 3. This document is a copy of the Colorado Court Rules 2018 as printed and ... The definitions are separated from the “General Instruction” and the “Verdict Form.” Burden of Proof - The appropriate burden of proof is included in each ... A defense is an affirmative defense if the defendant bears the burden of proof. ... within ten days after the jury has been discharged, may file a motion for ... This collection of jury instructions was compiled by the Civil Jury Instruction. Committee and is intended as a guide for judges and attorneys in constructing. A party is entitled to a jury instruction only when it is supported by the evidence and is consistent with existing law. Sufficient competent evidence ... It is the Plaintiff's burden to prove that [he] [she] lost wages and ... This Instruction is intended for use only when the Plaintiff claims unpaid minimum wage.