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US v. Clark Joint Proposed Jury Instructions

US v. Clark Joint Proposed Jury Instructions

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Published by NoloContendere

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Categories:Types, Business/Law
Published by: NoloContendere on Nov 22, 2012
Copyright:Attribution Non-commercial


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JOHN S. LEONARDOUnited States AttorneyDistrict of ArizonaKATHY J. LEMKEAssistant U.S. AttorneyTwo Renaissance Square40 North Central Avenue, Suite 1200Phoenix, Arizona 85004-4408Arizona State Bar No. 018468Telephone (602) 514-7500kathy.lemke@usdoj.gov
UNITED STATES DISTRICT COURTDISTRICT OF ARIZONAUnited States of America,Plaintiff,v.2. Randolph Benjamin Rodman, and6. Idan C. Greenberg,Defendants.CR-10-01047- PHX-ROS
The United States of America, by and through undersigned attorney, counsel for thedefendant Randolph Benjamin Rodman, Robert Sanders, and counsel for the defendant Idan C.Greenberg, Loyd C. Tate respectfully submit the following jury instructions to the Court andrequest that the same be given by the Court to the jury in the trial of the above-captioned matter.In addition, the parties request that the Court include the following standard instructions from theManual of Model Jury Instructions for the Ninth Circuit subject to objections noted by theindividual parties:Preliminary Instructions§ 1.1Duty of Jury§ 1.2The Charge – Presumption of Innocence (Modified)§ 1.3What is Evidence§ 1.4What is Not Evidence§ 1.5 Direct and Circumstantial Evidence
Case 2:10-cr-01047-ROS Document 431 Filed 11/19/12 Page 1 of 66
§ 1.6Ruling on Objections§ 1.7Credibility of Witnesses§ 1.8Conduct of the Jury§ 1.9 No Transcript Available to Jury§ 1.10 Taking Notes§ 1.11 Outline of Trial§ 1.13 Separate Consideration for Each DefendantInstructions in the Course of Trial§ 2.1Cautionary Instruction – First Recess§ 2.2Bench Conferences and Recesses§ 2.4Stipulations of Fact§ 2.10Other Crimes, Wrongs or Acts of Defendant (If applicable)Instructions at End of Case§ 3.1Duties of Jury to Find Facts and Follow Law§ 3.2Charge Against Defendant Not Evidence – Presumption of Innocence – Burden of Proof (Modified)§ 3.3 Defendant’s Decision Not to Testify (If applicable)§ 3.4Defendant’s Decision to Testify (If applicable)§ 3.5Reasonable Doubt - Defined§ 3.6What is Evidence§ 3.7What is Not Evidence§ 3.8Direct and Circumstantial Evidence§ 3.9Credibility of Witnesses§ 3.10 Activities Not Charged§ 3.13 Separate Consideration of Multiple Counts–Multiple Defendants§ 3.16 Intent to Defraud–Defined§ 3.17 Possession – Defined
Case 2:10-cr-01047-ROS Document 431 Filed 11/19/12 Page 2 of 66
Consideration of Particular Evidence§ 4.1Statements by Defendant§ 4.3 Other Crimes, Wrongs or Acts of Defendant (If applicable)§ 4.14Opinion Evidence, Expert Witness§ 4.15 Summaries Not Received in Evidence§ 4.16 Summaries Received in EvidenceResponsibility§ 5.1 Aiding and Abetting§ 5.6Knowingly - Defined§ 5.7 Deliberate IgnoranceJury Deliberations§ 7.1 Duty to Deliberate§ 7.2Consideration of Evidence–Conduct of the Jury§ 7.3Use of Notes§ 7.4Jury Consideration of Punishment§ 7.5Verdict Form§ 7.6Communication With CourtOffenses Under Title 18§ 8.21 Conspiracy to Defraud the United States§ 8.23 Conspiracy–Knowledge of and Association with Other Conspirators§ 8.68 Firearms–Transportation, Shipment, Possession or Receipt in Commerce WithRemoved or Altered Serial Number§ 8.121 Mail Fraud–Scheme to Defraud or to Obtain Money or Property by False Promises§ 8.122 Scheme to Defraud–Vicarious Liability§ 8.124 Wire FraudAdditional Offense Instructions26 U.S.C. §5861(g)- Obliteration, Alteration, Removal of a Serial Number
Case 2:10-cr-01047-ROS Document 431 Filed 11/19/12 Page 3 of 66

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