You have been asked to prepare a set of jury instructions and a verdict form for trial . . . for the first time. What do you do? Where do you start? And what does this have to do with appellate practice? Here, we offer some basic guidelines for drafting jury instructions and a verdict form, preparing for the charge conference, and preserving any error that may occur during or after the charge conference. The importance of having clear jury instructions, objections, and rulings thereon cannot be underestimated, as jury instructions are usually a fertile ground for appeal. Jury instructions are often reviewed de novo, because they involve questions of law, so it is imperative that you preserve all potential issues related to the instructions and verdict form.
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