Joint Request To Charge Page 9

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These are some of the factors you may consider in deciding whether to believe testimony
.
EXPERT TESTIMONY
You have heard testimony from persons described as experts, persons who, by education
and experience, have become expert in some field may state their opinion on matters in that field
and may also state their reasons for the opinion.
Expert opinion testimony should be judged just as any other testimony. You may accept
it or reject it, and give it as much weight as you think it deserves, considering the witness’s
education and experience, the reasons given for the opinion, and all the other evidence in the
case.
DEPOSITION TESTIMONY
During the trial, testimony was presented to you through a deposition. A deposition is the
sworn, recorded answers to questions asked a witness in advance of the trial. Under some
circumstances, if a witness cannot be present to testify from the witness stand, that witness
testimony may be presented, under oath, in the form of a deposition. Deposition testimony in
entitled to the same consideration and is to be weighed and otherwise considered by you insofar
as possible in the same way as if the witness had ben present and had testified from the witness
stand in court.
NOTE-TAKING
Some of you have taken notes during the trial. Remember that the notes are for your own
personal use. They are not to be given or read to anyone else and they are not to be used in place
of your memory.
I will now instruct you on the rules of law that apply in this case.
**********
DUTY TO DELIBERATE
Choose a foreperson. As Foreperson, you will preside over the deliberations and speak
for the jury here in court.

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