Free Proposed Jury Instructions - District Court of Colorado - Colorado

Case 1:04-cr-00103-REB-MEH

Document 1096-10

Filed 03/30/2007

Page 1 of 1

INSTRUCTION NO. G- 9 IMPEACHMENT BY PRIOR INCONSISTENCIES You have heard the testimony of [name of witness]. You have also heard that, before this trial, he made a statement that may be different from his testimony here in court. This earlier statement was brought to your attention only to help you decide how believable his testimony in this trial was. You cannot use it as proof of anything else. You can only use it as one way of evaluating his testimony here in court. If a person is shown to have knowingly testified falsely concerning any important or material matter, you obviously have a right to distrust the testimony of such an individual concerning other matters. You may reject all of the testimony of that witness or give it such weight or credibility as you may think it deserves.

Criminal Pattern Jury Instructions (Tenth Circuit), No. 1.10 (2005); O'Malley, Grenig, & Lee, Federal Jury Practice and Instructions, § 15.06 (5th ed. 2005) (combined).