Local Rule 51.1: Instructions to the Jury and Special Verdicts and Interrogatories
D. Del. — Civil rule
RULE 51.1. Instructions to the Jury and Special Verdicts and Interrogatories.
Unless otherwise ordered by the Court:
(a) Instructions 3 Business Days Before Pretrial Conference. Prior to the pretrial conference of any jury trial, counsel for all parties must confer about the instructions and, at least 3 business days before the pretrial conference, counsel for plaintiff shall file written instructions reasonably anticipated to be made upon which all parties agree. If there are differences that cannot be resolved, each party shall submit its own form of proposed jury instructions in the specific area or areas where there is disagreement, accompanied by citation to supporting authority.
(b) Format. The written instructions shall contain a table of contents. All proposed jury instructions shall carry a descriptive title and all pages of the proposed jury instructions shall be numbered in such a way as to identify, next to each number, whether it has been submitted jointly, by plaintiff(s) or by defendant(s).
(c) Special Verdict or Interrogatories 3 Business Days Before Pretrial Conference. Any party desiring a special verdict or interrogatories, as provided for in Fed. R. Civ. P. 49, must file a suggested form of special verdict or suggested interrogatories at least 3 business days before the pretrial conference.