Plaintiff__________________________ is the personal representative of

________________________ , deceased.

If, under the court’s instructions, you find that plaintiff____________ is

entitled to a verdict against the defendant, you must then award him damages in an amount that will reasonably compensate the estate for any special damages, such as medical expenses, which the decedent incurred before his death, and funeral expenses, provided that you find that such damages were actually suffered by the estate and were [proximately] [legally] caused by the act or omission upon which you base your finding of liability.

[Plaintiff__________________________________ is also entitled to recover, on behalf of

the estate, any penalties that the decedent would have recovered if he had lived.]

NEV. J.I. 10.18

NRS 41.085(5)


About the Author

Jay Young is a Las Vegas, Nevada attorney. His practice focuses on business law, business litigation, and acting as an Arbitrator and Mediator. Peers have named him an AV-Rated Lawyer, Best Lawyers, a Top 100 Super Lawyers in the Mountain States multiple years, and to the Legal Elite and Top Lawyers lists for many years. Mr. Young has been appointed a part time Judge, a Special Master to the Clark County, Nevada Business Court, as an arbitrator by the Nevada Supreme Court. He has been appointed as an arbitrator or mediator of well over 250 legal disputes from business disputes to personal injury matters. He has been named Best Lawyers for Arbitration. Mr. Young is a respected author of ten books, including A Litigator’s Guide to Federal Evidentiary Objections, A Litigator’s Guide to the Federal Rules of Evidence, and the Federal Court Civil Litigation Checklist.
Mr. Young can be reached at 702.667.4868 or at