INSTRUCTIONS TO JURY

(a)  Submission of Proposed Jury Instructions. In the case of a jury trial, written proposed jury instructions and any request for special interrogatories and special verdict forms must be prepared and filed by counsel at least fourteen (14) days prior to the date of trial, but the Court may, in its discretion, receive additional requests during the course of the trial.

Counsel must file proposed instructions and requests for special interrogatories and/or special verdict forms with the Clerk of Court. Each proposed instruction, request for special interrogatory, and/or special verdict must be numbered, must indicate the identity of the party presenting the same, and must contain citations of authority. Individual instructions must embrace one subject only, and the principle of law so embraced in any request for instruction must not be repeated on subsequent requests. The Court may require that proposed jury instructions, requests for special interrogatories, and/or special verdict forms should also be submitted in electronic format for use by the Court.

(b)  Objections to Requested Instructions. Requested instructions, together with any requests for special interrogatories and/or special verdicts, must be served upon the adverse party. The adverse party must, at least one (1) day prior to trial, specify objections to any of said instructions. Any objection must identify the instructions objected to by number, and specify distinctly the matter to which said adverse party objects. Objections must be accompanied by citations of authority in support thereof.

(c)  Objections to the Instructions Given by the Court. The trial judge must fix the time, place, and procedure for making objections to the judge’s charge to the jury. Objections must be made outside the presence of the jury and must be reported by the Court reporter in the transcript.

(d)  Instructions to the Jury. The jury must be instructed by the Court, as provided in Federal Rule of Civil Procedure 51 either before or after arguments by counsel, or both, at the Court’s election. The final jury instructions, as given by the Court, will be docketed and become a part of the permanent case file.

RELATED AUTHORITY

Fed. R. Civ. P. 51