Important Notes

*The Court is inclined to reference state jury instructions when dealing with state law issues.

**As directed in the Trial Management Order and the Local Rules of this jurisdiction, only a single joint submission of proposed jury instructions with counter-proposals by each party is to be filed. The Court will not accept separate filings by each party of proposed jury instructions. Only a limited explanation, with limited case citations in support of the competing proposals (that is, a short and to the point explanation for support of the proposed instruction or the basis of the objection) is allowed.

***Proposed voir dire by each party, subject to the limitation of no more that a total of ten (10) additional voir dire questions by each side, is to be filed in a joint submission. The Court will not accept separate filings by each party of proposed voir dire.