In addition to being filed, proposed jury instructions should also be submitted to the chambers mailbox in Word Perfect or Microsoft Word format, by e-mail to Judge Simon's chambers mailbox.

Parties should only submit jury instructions for issues not covered by this set of boilerplate instructions dealing with standard trial matters:

General Civil Jury Instructions

Where an applicable Seventh Circuit Pattern Instruction exists, Judge Simon is inclined to use it unless a party makes a strong showing of its inappropriateness.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Jury instructions from Judge Simon's prior civil trials are below.