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A reasonable doubt is not a mere possible doubt, a speculative, imaginary or forced doubt. Such a doubt must not influence you to return a verdict of not guilty if you have an abiding conviction of guilt.
For a court to instruct the jury on the insanity defense, the defendant must, by clear and convincing evidence, show only that a reasonable juror could conclude that the defendant was legally insane at the time of the crime.
Punitive damages are warranted against (defendant) if you find by clear and convincing evidence that (managing agent, primary owner, or other person whose conduct may warrant punitive damages without proof of a superior's fault) [was] [were] personally guilty of [intentional misconduct] [or] [gross negligence], which ...