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1 PJI 2 | RULES OF LAW
DIRECTIONS TO LAWYERS CONCERNING PREPARATION OF PROPOSED INSTRUCTIONS
PREPARE FOR INSERTION HERE YOUR PROPOSED INSTRUCTIONS CONCERNING THE CLAIMS AND DEFENSES, SPECIAL ISSUES AND DAMAGES IN THE FOLLOWING FORMAT AND SEQUENCE.
[Note that Judge Hornby has drafted proposed pattern jury instructions following First Circuit law for cases of employment discrimination, excessive force, railroad employee personal injury and maritime employee personal injury. They are available on-line at the District of Maine website: http://www.med.uscourts.gov.]
1. Description of the plaintiff’s claim(s), followed by:
A. Enumeration of the essential elements of the claim(s);
B. Definition of key terms used in enumerating the elements of the claim(s); and other special instructions, if any, necessary to further explain or qualify the claim(s).
2. Description of the defendant’s defense(s) and counterclaim(s), if any, followed by:
A. Enumeration of the essential elements of the defense(s) and counterclaim(s), if any;
B. Definition of key terms used in enumerating the essential elements of the defense(s) and counterclaims; and other special instructions, if any, necessary to explain further or qualify the defense(s) and/or the counterclaim(s).
3. Enumeration of plaintiff’s (and counterclaimant’s) recoverable elements of damage and explanation, as appropriate, of each element.
NOTE: In submitting your proposed instructions it is not necessary to duplicate or request the Court’s standard instructions that precede and follow Section II. Those instructions will be given in every case, subject to deletion of irrelevant instructions (e.g., delete expert instruction if no expert).
Congratulations! You're now booked up on Pattern Jury Instruction 1 PJI 2 (US District Courts - 1st Circuit)!
You might need to reference it during your pursuit of justice.
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