Local Rule LR51.1: Jury Instructions.

LR51.1. Jury Instructions.

Unless otherwise ordered, jury instructions must be submitted consistent with the following:

(a) Each instruction must begin on a separate page, must be numbered consecutively, and must cite to the model or uniform jury instruction number, where applicable. The principle stated in one instruction should not be repeated in any other instruction.

(b) All instructions should be concise, clear, understandable, and contain neutral statements of law. Argumentative instructions are improper, will not be given, and should not be submitted.

(c) A judge may have designated a set of standard jury instructions that can be found on the court's website under "Judges' Requirements." If so, these jury instructions should be considered for inclusion.

(d) Any modifications of the Ninth Circuit Model Jury Instructions or any other form instructions must specifically identify the modification made and the authority supporting the modification.

(e) The parties shall serve their proposed instructions upon each other at least twenty-one (21) days prior to trial. The parties must then meet, confer in good faith, and submit one complete set of agreed upon instructions.

(f) If the parties cannot agree on one complete set of instructions, they shall submit one set of those instructions on which agreement was reached, and each party should additionally submit a separate set of proposed instructions on which agreement could not be reached.

(g) These jointly agreed upon instructions and separately proposed instructions must be filed at least fourteen (14) days prior to trial. Each party should then file, at least seven (7) days before trial, its objections to the instructions proposed by the other party. All objections shall be in writing and shall set forth the proposed instruction in its entirety. The objection shall then specifically set forth each objectionable matter in the proposed instruction including any argument and citation to authority explaining the basis of the objection. When applicable, the objecting party shall submit an alternative instruction covering the subject or principle of law.

(h) In addition to filing the instructions, the parties shall concurrently submit an electronic copy of their agreed upon and separately proposed instructions to the court by e-mail in Word format unless otherwise directed by the court.

(i) The trial judge shall schedule a hearing to settle any jury instructions that have not been agreed upon.

(j) Failure to comply with any requirement of this rule may result in sanctions in accordance with LR11.1.