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51.1 Requests for Instructions to Jury

(a) Requests for instructions to the jury must be filed with the court and served upon each adverse party in accordance with the deadline set by the court in the scheduling order. The proposed instructions to the jury must encompass all rules of law applicable to the evidence adduced. Appropriate citations should be noted following the text on each page of the charge to the jury.

(b) The court may receive additional requests for instructions to the jury relating to questions or issues arising during the trial at any time prior to the closing arguments. The parties submitting such late proposed instructions must be prepared to explain to the court both the need for the additional instruction and the reason for its omission from the instructions proposed before trial.

(c) Proposed instructions to the jury must be served upon opposing parties when they are filed with the court, in accordance with the scheduling order.