California, United States of America
The following excerpt is from Sanchez v. Maxwell, B260981 (Cal. App. 2016):
Stipulations as to liability but not to causation are common in auto accident cases, because "[s]ome acts or omissions accurately classified as 'negligent' (i.e., a breach of defendant's duty of care) do not necessarily have a causal role in motor vehicle accidents." (Bermudez v. Ciolek (2015) 237 Cal.App.4th 1311, 1321.) So common are such stipulations that a standard jury instruction has been developed for use at trial, CACI No. 424. The "directions for use" that accompany CACI No. 424 expressly state that it is "intended for cases in which the defendant 'admits' liability, but contests causation and damages." (Use Note to CACI No. 424 (2015 ed.) p. 263.)
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