Free Proposed Jury Instructions - District Court of Colorado - Colorado

Case 1:04-cv-01067-MSK-CBS

Document 117-3

Filed 05/26/2006

Page 1 of 1

Pa t 'O j t nt D fn a t Po o e Is u t n N . 5a d1 lnis b co o ee d n' rp s d n t co s o 1 n 6 if f ei s r i And/or COMPETING Instruction No. 15 and No. 16

In its proposed jury instructions No. 15 and 16, Defendant seeks to place before tej y h tx o tos co s fh C l a o"l h e fei tr e s ns tt: h u te e t fw e t n o te o rd o i "i f he p n i t ue r i o d r rg o a C.R.S. §31-30.5-604 and C.R.S. §31-30.5-705. Plaintiff objects to the introduction or use of these two proposed instructions on the ground that they effectively call upon the jury to consider and interpret statutes and draw legal conclusions, which are not its province, and to consider matters which are not determinative in or relevant to their deliberations on the question of whether Defendant violated federal statutes. Their use in this fashion will only contribute to confusion of the issues in the minds of the jury members.