Proposed jury instructions should be filed of record in the docket of the case.
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.
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 criminal trials are below.
| Case Name | Charges | Trial Year |
|---|---|---|
| U.S. v. Shelby | Possession w/ intent to distribute | 2005 |
| U.S. v. Kolep | Felon in possession of firearm | 2005 |
| U.S. v. Valdez | Possession w/ intent to distribute | 2005 |
| U.S. v. Parr | Felon in possession of firearm/ammunition | 2005 |
| U.S. v. Trzeciak | Felon in possession of firearm | 2005 |
| U.S. v. Ross | Felon in possession of firearm/ammunition | 2005 |
| U.S. v. Heredia | Interstate domestic violence/stalking | 2006 |
| U.S. v. Candiano | Interstate commerce - coercion/enticement of minor | 2006 |
| U.S. v. Price | Felon in possession of firearm | 2006 |
| U.S. v. Lawson | Possession w/ intent to distribute | 2006 |
| U.S. v. Cyprian | Possession w/ intent/felon in possession of firearm/ammunition | 2006 |
| U.S. v. Cochran | Interstate commerce - coercion/enticement of minor | 2007 |
| U.S. v. Rouhselang | Interstate commerce - coercion/enticement of minor | 2007 |
| U.S. v. Jenkins | Felon in possession of firearm | 2007 |
| U.S. v. Maxwell | Conspiracy/selling or offering for sale drug paraphernalia | 2007 |
| U.S. v. Bennett, Loera | Conspiracy/possession w/ intent to distribute | 2007 |
| U.S. v. Mannava | Interstate commerce - coercion/enticement of minor | 2007 |
| U.S. v. Prieto, Sanz | Possession w/ intent to distribute | 2007 |
| U.S. v. Edwards | Possession w/ intent to distribute | 2007 |
| U.S. v. Hensley | Interstate commerce - coercion/enticement of minor | 2007 |
| U.S. v. Sims | Narcotics- and weapons-related crimes | 2007 |
| U.S. v. Harris, Smith, Powell | Wire fraud/conspiracy/signing false income tax return | 2007 |
| U.S. v. Hawkins | Possession of firearm in furtherance of drug trafficking | 2007 |
| U.S. v. Winbush | Narcotics- and weapons-related crimes | 2007 |
| U.S. v. Wilson, Hardimon | Conspiracy to possess w/ intent to distribute | 2008 |
| U.S. v. Olimpo | Distribution of narcotics | 2008 |
| U.S. v. Martin | Possession of narcotics/felon in possession of firearm | 2008 |
| U.S. v. Allen, Joshua, Karras | Scheme to defraud/mail fraud | 2009 |
| U.S. v. Mota | Attempt to distribute narcotics | 2009 |
| U.S. v. Jordan, Adkins | Possession w/ intent to distribute/felon in possession of firearm | 2010 |
| U.S. v. Spears | Possession w/ intent to distribute/felon in possession of firearm | 2010 |
| U.S. v. Ramirez-Fuentes | Possession w/ intent to distribute/felon in possession of firearm | 2011 |
| U.S. v. United Water, Bowie, Ciaccio | Conspiracy/Clean Water Act violations | 2012 |
| U.S. v. Harris, Sanders | Conspiracy/credit card fraud | 2013 |
| U.S. v. Smith | Narcotics- and weapons-related crimes | 2013 |
| U.S. v. McClellan | Money laundering/mail fraud/scheme to defraud | 2013 |
| U.S. v. Reyes | Murder/conspiracy/narcotics- and weapons-related crimes | 2014 |
| U.S. v. Tartareanu | Conspiracy/wire fraud | 2014 |
| U.S. v. Briseno | Murder/conspiracy/narcotics- and weapons-related crimes (GUILT PHASE) | 2015 |
| U.S. v. Briseno | Murder/conspiracy/narcotics- and weapons-related crimes (SENTENCING PHASE) | 2015 |
| U.S. v. Bradbury | Interstate commerce -- threat/maliciously convey false information | 2015 |
| U.S. v. Fadiga | Possession of access devices w/intent to defraud | 2016 |
| U.S. v. Laviena | Murder/use of firearm during crime of violence | 2017 |