How To Use The Pattern Instructions
These instructions will function best if specific references to the case being tried are inserted. For example, every time we have put the word defendant in brackets we intend the instructing judge to substitute the defendantís actual name. The same holds true when the word witness is bracketed. General studies of juror understanding suggest that juries understand better when actual names are used rather than terms like defendant or witness. On the same rationale, we have used the term I rather than the third person the court when referring to the judge. Finally, where we have given alternatives, you should select the alternative(s) that best fit(s) the evidence in your case.