court did not err in excluding evidence of labor savings for the time period following the strike. The Unions, as the breaching party, have the burden of proving that “the breach resulted in a direct and immediate savings to the plaintiff,” Macon-Bibb, 530 F.Supp. at 1055, and they have failed to meet this burden. Just as the plaintiff must prove his damages with reasonable certainty, Dobbs, supra § 3.3, at 148, the defendant must prove the amount of the offset with reasonable certainty, id. § 3.6, at 185. The evidence offered by the Unions’ expert on the offset issue focused solely on one cost component: labor costs. This self-serving analysis failed to examine the total economic effect of the breach upon Morrell. See Lewis v. Benedict Coal Corp., 259 F.2d 346, 353 (6th Cir.1958) (<HOLDING>), modified on other grounds, 361 U.S. 459, 80
holding that contract language referring to amount of loss authorized appraiser only to place dollar value on loss and not to determine cause of damage or other coverage issues holding that the damage formula was erroneous because it measured only increased costs rather than actual profit or loss holding that the loss of trade secrets cannot be measured in money damages holding the defendant responsible for the greater of the actual or intended loss holding that termite damage does not fall within the meaning of property damage in the policy because the alleged misrepresentations did not cause the damage the termites did