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Focus (Forum & Focus)

Jun. 9, 2009

Instructions Manual

There are many potential potholes on the jury instruction road, writes Jens Koepke.

FOCUS COLUMN

By Jens B. Koepke

"A party is entitled upon request to correct, nonargumentative instructions on every theory of the case advanced by him which is supported by substantial evidence." Soule v. General Motors Corp., 8 Cal.4th 548 (1994). Sounds simple, right? But there are many potential potholes on jury instruction road. How you prepare proposed instructions, keep track of what happens to them during trial and make a clear recor...

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