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PATTERN JURY INSTRUCTIONS WHICH PROVIDE A BODY OF BRIEF, UNIFORM INSTRUCTIONS THAT FULLY STATE THE LAW WITHOUT NEEDLESS REPETION ARE PRESENTED; BASIC, SPECIAL, OFFENSE, AND TRIAL INSTRUCTIONS ARE INCLUDED.
The idea behind a limiting instruction is that it is better to admit relevant and probative evidence, even in a limited capacity, and take the chance that the jury will properly apply it in its decision making, rather than to exclude it altogether.
Punitive Damages [Name of defendant] consciously pursued a course of conduct knowing that it created a substantial risk of significant harm to others. To prove this required state of mind by clear and convincing evidence, [name of plaintiff] must persuade you that the punitive damages claim is highly probable.
The Texas Pattern Jury Charges series is widely accepted by attorneys and judges as the most authoritative guide for drafting questions, instructions, and definitions in a broad variety of cases.
Jury instructions are instructions for jury deliberation that are written by the judge and given to the jury. At trial, jury deliberation occurs after evidence is presented and closing arguments are made.
The judge will advise the jury that it is the sole judge of the facts and of the credibility (believability) of witnesses. He or she will note that the jurors are to base their conclusions on the evidence as presented in the trial, and that the opening and closing arguments of the lawyers are not evidence.