Ultimately, Bloom told the jurors that all evidence has been received, that they should rely on their collective memories and that they should refer to jury instructions, which state, “If you find for the Estate of David Kleiman and/or W&K on any of its claims, you must consider the matter of damages. Generally, you should award an amount of money that the preponderance of the evidence shows will fairly and adequately compensate the Estate of David Kleiman and/or W&K for its damages.”