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Jury Instructions and Trial Exhibits

Counsel shall use the Pattern Civil Jury Instructions for the Seventh Circuit, copies of which are available on the court’s website ( Devitt & Blackmar, Federal Jury Practice and Instructions is the preferred source for state law claims. Verdict forms shall be captioned with the case name and number.

For jury trials, the court will insist on strict compliance with Footnote 10 of paragraph 2(i) of the Final Pretrial Order Form 16.1.1. This provision reads as follows:

Agreed instructions shall be presented by the parties whenever possible. Whether agreed or not, each marked copy of an instruction shall indicate the proponent and supporting authority and shall be numbered. All objections to tendered instructions shall be in writing and include citations of authorities. Failure to object may constitute a waiver of any objection. [Emphasis in original.]

It is the duty of the plaintiff’s counsel to prepare the first draft of jury instructions, keeping in mind that the parties are expected to agree on all instructions other than those about which there is a genuine, material dispute. All parties must confer in good faith to accomplish this goal.

Sufficient copies of jury instructions should be provided for counsel, the entire jury, and two additional copies for the court.

See the judge’s handout on "Trial Preparation and Procedures" for information on trial exhibits.

After completion of the trial, counsel are directed to make arrangements with the judge’s staff for removal of all exhibits, including binders, easels, and any audio/video equipment. The cloak room adjacent to the courtroom is not a storage room for counsel’s trial exhibits after the verdict is returned. Any trial materials not removed within 14 days after the trial is finished will be discarded.

Note: The court does not control nor can it guarantee the accuracy, relevance, timeliness, or completeness of this information. Neither is it intended to endorse any view expressed nor reflect its importance by inclusion in this site.