Arguing jury instructions

The jury goes back into the deliberation room with two items:  1)  exhibits; 2) written instructions.

It isn't good enough to simply submit your instructions.  You have to argue for them. And if you lose, you have to create a record in the event of appeal.

Here is the transcript of the instruction argument from a trial I handled with my law partner Kevin Coluccio.

Click here for argueinstructions.pdf.