The parties must meet and confer to discuss jury instructions in advance of the Final Pretrial Conference. At that time, they must make a genuine good faith effort to narrow their disputes and to discuss each instruction collaboratively to reach agreed-upon text. The parties must jointly submit one set of Stipulated Proposed Jury Instructions. At the same time, for any disputed instruction, the parties must separately submit a set of Proposed Alternative Jury Instructions with objections and commentary.

Each jury instruction must be on a separate page and cite the specific legal authority that supports it, unless one does not exist. Each set of jury instructions must contain a Table of Contents and an Index. The Court has its own standard introductory and concluding instructions, and therefore counsel are directed to concentrate on the jury instructions related to their respective claims and defenses.