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It is entirely property for a lawyer to
talk to a witness about what testimony the witness would
give if called to the courtroom. The witness should not
be discredited by talking to a lawyer about his or her
testimony.

Your verdict should not be influenced by
feelings of prejudice, bias, or sympathy. Your verdict
must be based on the evidence and the law contained in
these instructions.

Deciding a verdict is exclusively your
job. I cannot participate in that decision in any way.
Please disregard anything that I may have said or done
that made you think that I preferred one verdict over the
other.

In just a few moments you will be taken to
the jury room. The first thing that you need to do is is
to elect a foreperson. The foreperson presides over your
deliberation like a chairperson of a meeting. It is the
foreperson’s job to sign and date the verdict form when
all of you have agreed on a verdict in this case. For
your convenience we have prepared one for you. You will
take it back with you. It read, “We, the jury finds as
follows as to the Defendant in this case.” You have two
choices. A choice “A” the Defendant is guilty of
Battery as charged. Choice “B” the Defendant is not