5031 punitive damages bifurcated procedure 5032

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503.1 Punitive Damages - Bifurcated Procedure 503.2 Punitive Damages - Non-Bifurcated Procedure SECTION 600 - SUBSTANTIVE INSTRUCTIONS — GENERAL 601.1 Weighing the Evidence 601.2 Believability of Witnesses 601.3 Jury to Be Guided by Official English Translation/Interpretation 601.4 Multiple Claims, Numerous Parties, Consolidated Cases 601.5 Concluding Instruction (Before Final Argument) SECTION 700 - CLOSING INSTRUCTIONS 700 Closing Instructions SECTION 800 - SUPPLEMENTAL MATTERS 801.1 Juror Questions During Deliberations 801.2 Read-Back of Testimony 801.3 Jury Deadlocked 801.4 Instructions upon Discharge of Jury MODEL JURY INSTRUCTIONS Summary The following Model Jury Instructions are included to illustrate the use of Florida Standard Jury Instructions . The hypothetical facts upon which each instruction is based are set forth before the instruction. The committee made arbitrary decisions about various factors involved in each hypothetical case, and the Model Instructions are not intended to be incorporated entirely into a court’s instruction. The numbers of the instructions used in the examples are indicated within brackets. In instances in which changes have been made to adapt the standard instructions to the
circumstances of the hypothetical case, the committee has italicized the instructions. These Model Instructions are provided only as examples of how the instructions are intended to be used. Revisions in the Model Instructions often lag some time behind revisions in the substantive charges the use of which is illustrated in the Model Instructions. DO NOT, therefore, rely on the Model Instructions for correct wording when preparing instructions. Always refer to the standard instructions and forms provided in Parts I through VIII. Model Instruction No. 1 : Automobile collision; comparative negligence; single claimant and defendant; no counterclaim; no-fault issue; witnesses testifying in foreign language; instructions for beginning and end of case; use of special verdict in burden of proof and damage instructions Model Instruction No. 2 : Automobile collision; driver’s comparative negligence including failure to wear seat belt; aggravation of pre-existing injury; multiple events Model Instruction No. 3 : Automobile collision; comparative negligence; wrongful death damages; Fabre issue Model Instruction No. 4 : Automobile collision; comparative negligence; claim and counterclaim Model Instruction No. 5 : Injury in three-car collision; settlement with injured party by one tortfeasor; independent contribution claim by him against others; reasonableness of settlement as well as liability contested Model Instruction No. 6 : Claimant suing three alleged joint tortfeasors; comparative negligence in issue; contribution shares to be determined in action Model Instruction No. 7 : Product liability case; negligence and strict liability claims; comparative negligence defense; aggravation of pre-existing injury VERDICT FORMS The following Model Verdict forms are included as examples of how issues can be submitted to the jury. They may be changed on a case-by-case basis depending on the rulings and facts

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