Jury Instructions

• Author: Leonard H. Bucklin
• Pages: 369-372

21. Jury Instructions

In this section, keep notes of thoughts you have as you work up the case regarding

your requested instructions. When you have completed your requested jury instruc-

tions, place a double-sided copy here. When the judge gives you his draft or final ver-

sion, put the judge’s instructions here. Do the same when your adversaries give you a

copy of what they have requested the judge to charge.

Having your requested instructions, the adversary’s requests, and the judge’s draft

instructions in one place makes arguments and references easy at a critical time in the

trial. You can open your trial notebook and flip to either the live pleadings, or the notes

of what a witness said in the trial, or to requested instructions, or to the judge’s draft

instructions, during any in-chambers session with the judge.

Further, when the jury is deliberating and the bailiff says, “The judge wants to see

you in chambers; the jury has a question,” grab your trial notebook. It will have every-

thing you need to reference.

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