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124.

Sample Jury Instructions -- Food Fraud -- Pattern Instructions

Comes the United States of America, by counsel, and requests that the Court give the attached jury instructions. Pursuant to this Court's admonition in its March 7, 1994, Trial Scheduling Order, the Government is submitting substantive instructions only.The Government would respectfully requests that the Court include in its basic instruction the following instructions from the Sixth Circuit's Pattern Criminal Jury Instructions (West 1991):

NOTE: Included with this submission are requested modifications to those basic instructions followed by an "*".

Instruction No. Instruction

1.01 Introduction

1.02 Juror's Duties

1.03 Presumption of Innocence, Burden of Proof, Reasonable Doubt

1.04 Evidence Defined

1.05 Consideration of the Evidence

1.06 Direct and Circumstantial Evidence

1.07 Credibility of Witnesses

1.08 Number of Witnesses

2.01 Introduction

2.01C Separate Consideration--Multiple Defendants Charged with the Same Crimes

Instruction No. Instruction

2.04 On or About

2.08 Inferring Required Mental State

2.09* Deliberate Ignorance

3.01A, 3.01B* Conspiracy to Commit an Offense; Conspiracy to Defraud the United States -- Basic Elements

3.02 Agreement

3.03 Defendant's Connection to the Conspiracy

3.04 Overt Acts

3.06 Unindicted, Unnamed or Separately Tried Co-Conspirators

3.10 Pinkerton Liability for Substantive Offenses Committed by Others

4.01 Aiding and Abetting

The Government requests permission to supplement or modify these instructions as further pretrial developments and the evidence at trial may warrant.

Dated: _____________, 1994 Respectfully submitted,

MICHAEL TROOP United States Attorney

________________________________ William F. Campbell Assistant United States Attorney 510 West Broadway, 10th Floor Louisville, Kentucky 40202 (502) 582-5911 ________________________________ Kenneth L. Jost Assistant Director ________________________________ James E. Arnold Attorney Office of Consumer Litigation U.S. Department of Justice P.O. Box 386 Washington, D.C. 20044 (202) 307-0048/(202) 307-0174

[cited in USAM 4-8.235; 4-8.245]