Instructions for Compiling Jury Instructions in Civil Cases

1. Counsel should collaborate to compile a joint set of instructions.  Plaintiff’s counsel is primarily responsible for the burden of proof instructions, damages instructions, verdict forms, and verdict instructions, and Defendant is primarily responsible for the cautionary instructions, but the parties shall work together to compile one joint set.
     

2. The agreed upon instructions should be labeled as “Joint Instruction No. ____” and numbered consecutively by counsel.  Instructions on which counsel cannot agree should similarly be labeled “Plaintiff’s Proposed Instruction No. ____” or “Defendant’s Proposed Instruction No. ____” and numbered consecutively by counsel.  The number on the proposed instructions should not be left blank.
     

3. Counsel SHALL NOT provide a clean copy of the proposed instructions.  Only one set, which identifies the source of the proposed instruction and the number designation noted above, should be tendered.  
     

4. Counsel shall email to the court at GPMpd@ilsd.uscourts.gov all of the instructions in WordPerfect format saved as one document. Only the instructions which are not agreed upon should be submitted as a separate document, if necessary. 
     

5. The Court will review and edit the proposed instructions and print a final, consolidated set once all objections have been resolved.  Each juror is given an individual set of clean instructions, and an enlarged copy of the clean instructions is shown on television screens in the courtroom while the instructions are read to the jury.
     

6. Counsel for each party shall retain a copy of the instructions that have been submitted for formal tendering to the Court during the jury instruction conference.  The instructions submitted during the final pretrial conference are not considered “tendered.”
     

7. The Court prefers the Seventh Circuit Pattern Instructions when available and appropriate; otherwise, the Court prefers the Illinois Pattern Instructions (I.P.I.).  

8. Counsel should contact the law clerk assigned to the case to inquire whether the Court has a set of instructions which were given in a similar case in the past.

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