K:\BATAILLO\JFB\WPPUB\CASES\CIVIL\Withers\FINAL ji.PDF



IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKASALLY WITHERS,)8:01CV626)Plaintiff,))vs.)FINAL)JURY INSTRUCTIONSMUTUAL PROTECTIVE INSURANCE) COMPANY,)) Defendant.)INSTRUCTION NO. 1DUTYIt will be your duty to decide from the evidence whether the plaintiff is entitled to a verdict against the defendant. From the evidence, you will decide what the facts are. You are entitled to consider the evidence in the light of your own observations and experiences in life. You may use reason and common sense to draw deductions from facts established by the evidence. You will then apply those facts to the law which I give you in these and the other instructions. In that way, you will reach your verdict. You are the sole judges of the facts; but you must follow the law as stated in my instructions, whether you agree or disagree with the law stated in the instructions.Do not allow sympathy or prejudice to influence you. The law requires that your verdictbe unaffected by anything except the evidence, your common sense, and the law stated in these and other instructions.Anything that I may say or do during the trial must not be taken by you as an indicationof what I think of the evidence or what I think your verdict should be.EVIDENCEThe word "evidence" includes the testimony of witnesses; documents and other things received as exhibits; any facts that have been stipulated, that is, formally agreed to by the parties; and any facts that have been judicially noticed, that is, facts which I say you must accept as true.The following things are not evidence:1.Statements, arguments, questions and comments by lawyers are not evidence.2.Objections are not evidence.Lawyers have an obligation to their clients to object when they believe that the evidence being offered is improper under the rules of evidence. You should not be influenced by the lawyer’s objection or by my ruling on it. If I sustain an objection to a question, ignore the question. If I overrule the objection, treat the answer like any other answer. If so, do not attempt to draw any inference in favor of either side as the result of any ruling I make. Finally, if I instruct you that some item of evidence is received for a limited purpose only, you must follow that instruction. Pay particularly close attention to this sort of limiting instruction, because it may not be available to you in writing later in the jury room.3.Testimony that I strike from the record or tell you to disregard isnot evidence and must not be considered.4.Anything you see or hear about this case outside this courtroom is not evidence and must be disregarded.Finally, some of you may have heard the phrases or terms "direct evidence" and "circumstantial evidence." Direct evidence is direct proof of a fact, such as testimony by an eye witness. Circumstantial evidence is proof of facts from which you may infer or conclude that other facts exist. The law makes no distinction between the weight to be given to either direct or circumstantial evidence. You should give the evidence the weight that you believe the evidence is entitled to receive.BENCH CONFERENCES AND RECESSESDuring the trial it may become necessary for me to talk with the lawyers outside your hearing, either by having a bench conference while you are present in the courtroom, or by calling a recess. Please understand that while you are waiting, the court and counsel are working. The purpose of these conferences is to decide how certain evidence is to be treated under the rules of evidence or to decide a particular procedure to be followed in the case. We will, of course, do what we can to minimize the number and length of these conferences.JURY QUESTIONSWhile evidence is being presented, you are not allowed to raise your hands to ask questions about that evidence. However, if you do have questions about something you hear during the examination of a witness, you may write your questions down on a piece of paper. When attorneys have finished examining that witness, you may submit your written question or questions. I will review each question with the attorneys. You may not receive an answer to your question because I may decide that the question is not proper under the rules of evidence. The attorneys may choose to answer your questions by asking more questions of the witness. But even if the question is proper, you may not get an immediate answer to your question. For instance, a witness or an exhibit that you will see later in the trial may answer your question.NOTE-TAKINGIf you wish, you may take notes to help you remember what witnesses said. Notes may be helpful to you because at the end of the trial, you must make your decision based on what you recall of the evidence. You will not have a written transcript to consult, and it may not be practicalfor the court reporter to read back lengthy testimony. Therefore, you should pay close attention to the testimony as it is given.If you do take notes, please keep them to yourself until you and the other jurors go to the jury room to decide this case. However, do not let note-taking distract you to the point that you miss hearing other testimony from the witness.During the trial, documents or other physical items may be received into evidence. At the present, however, you will not be supplied with a list of exhibits which are received in evidence. Therefore, you may wish to make notes about the exhibits, especially their description and number, so that you can refer to those exhibits while you are deliberating.When we take our recess each day for the lunchtime break and when we take our recess each night, please take your notes to the jury room and leave your notes there. The courtroom deputy will take custody of your notes and secure them.No one will read your notes but you. Your notes will be destroyed after the trial is over.IMPARTIALITYThis case should be considered and decided by you as an action between persons of equal standing in the community and of equal worth. A large corporation is entitled to the same fair trial as a small corporation. All parties stand equal before the law and are to be dealt with as equals in a court of justice.PREPONDERANCE OF EVIDENCEYour verdict depends on whether you find certain facts have been proven. The burden of proving a fact is upon the party whose claim or defense depends on that fact. The party who has the burden of proving a fact must prove it by the greater weight of the evidence, also known as a “preponderance of the evidence.”By a "preponderance of the evidence," I mean the greater weight of credible evidence. This is not determined by which party has the greater number of witnesses testifying about the facts and circumstances or by the number of exhibits. Preponderance of the evidence is determined by the amount of evidence which on the whole, when fully, fairly and impartially considered, makes the stronger impression on your mind and is more convincing as to its truth when weighed against the evidence the other party has presented.To prove something by a preponderance of evidence is to prove that it is more likely true than not. Each party is entitled to the benefit of any evidence tending to establish a claim, even though the other party introduced that evidence. If the evidence is equally balanced, a preponderance is not established.You may have heard the term “proof beyond a reasonable doubt.” That is a stricterstandard that applies in criminal cases. It does not apply in civil cases such as this one. You should, therefore, put the term out of your minds.WITNESSESIn deciding what the facts are, you may have to decide what testimony you believe and what testimony you do not believe. You may believe all of what a witness said, or only part of it, or none of it.In deciding what testimony to believe, consider the witness’s intelligence, the opportunity the witness had to have seen or heard the things testified about, the witness’s memory, any motives that witness may have for testifying a certain way, the manner of the witness while testifying, whether that witness said something different at an earlier time, the general reasonableness of the testimony, and the extent to which the testimony is consistent with any evidence that you believe.In deciding whether or not to believe a witness, keep in mind that people sometimes hear or see things differently and sometimes forget things. You need to consider therefore whether a contradiction is an innocent misrecollection or lapse of memory or an intentional falsehood, and that may depend on whether it has to do with an important fact or only a small detail.The fact that one side may use a greater number of witnesses or present a greater quantity of evidence should not affect your decision. Rather, determine which witness or witnesses and which evidence appears accurate and trustworthy. It is the weight of the evidence that counts -- not the number of witnesses.If the testimony of a single witness produces in your minds a belief in the likely truth ofany fact and would justify a verdict in accordance with the witness’s testimony, even though a number of witnesses may have testified to the contrary, and you have considered all of thewitness.CONDUCT OF THE JURYTo insure fairness, jurors are asked to obey the following rules:First, do not talk among yourselves about this case, or about anyone involved with this case, until the end of the case when you go to the jury room to decide on your verdict.Second, do not talk with anyone else about this case, or about anyone involved with it, until the trial has ended and you have been discharged as jurors.Third, during this trial when you are outside this courtroom, do not listen to or let anyone try to tell you anything about this case. Do not let anyone talk to you about anyone involved with this case until the trial has ended and I have accepted your verdict. If anyone tries to talk to you about this case during the trial, please promptly report the matter to me.Fourth, during the trial you should not talk with or speak to any of the parties, lawyers or witnesses involved in this case, which means that you should not even pass the time of day with any of them. If a person from one side of the lawsuit sees you talking to a person from the other side, even if it is on a matter unconnected with this trial or simply to pass the time of day, such contact might arouse an unwarranted suspicion about your fairness. If a lawyer, party or witness does not speak to you when you pass in the hall, ride the elevator, or encounter each other elsewhere while this trial is taking place, do not think he or she is being rude. Those persons are not supposed to talk or visit with you, either.Fifth, you must decide this case on the basis of evidence presented in the courtroom.Therefore, do not read any news stories or articles about the case, or about anyone involved with this case, or listen to any radio or television reports about the case or about anyone involved with it. In fact, until the trial is over youshould probably avoid reading any newspapersor news journals, and avoid listening to any TV or radio newscasts. There might not be any news reports of this case, but, if there are, you might find yourself inadvertently reading or listening to something before you realize what you are doing.Sixth, do not do any research or make any investigation on your own concerning this case. Do not use or refer to a dictionary or any law books concerning any aspect of this case, including any evidence introduced. Do not visit the scene of any incident that may have been mentioned in this case.Seventh, do not form an opinion about any fact or issue in the case until you have received the entire evidence, have heard arguments of counsel, have been instructed as to the law of the case, and have retired to the jury room. Consequently, do not make up your mind during the trial about what the verdict should be. Keep an open mind until after you have gone to the jury room to decide the case and have discussed the evidence with the other jurors.Finally, do not be influenced by sympathy or prejudice. Do not indulge in any speculation, guess, or conjecture. And do not make any inferences which are not supported by the evidence.OUTLINE OF TRIALThe trial will proceed in the following manner:First, the attorney for the plaintiff may make an opening statement. Next, the attorney for the defendant may make an opening statement. An opening statement is not evidence or argument. It is an outline of what the party intends to prove, a summary of what the attorney expects the evidence to be.The plaintiff's attorney will then present evidence through a direct examination of a witness. The defendant’s attorney may then cross-examine that witness. After the cross- examination, the plaintiff’s attorney may ask additional questions on re-direct. The defendant’s attorney may also ask questions on re-cross. After the plaintiff has presented all her witnesses, the plaintiff will rest. The defendant will then present its case. The defendant may present evidence through direct examination of witnesses and plaintiff’s attorney may cross-examine those witnesses. Re-direct and re-cross examinations may also take place.After the evidence is completely presented, the attorneys will make their closing arguments to summarize and interpret the evidence for you. Just as with opening statements, these closing arguments are not evidence. I will then instruct you further on the law. After that you will retire to the jury room to deliberate on your verdict.STATEMENT OF THE CASEThe plaintiff, Sally Withers, alleges that her former employer, the defendant Mutual Protective Insurance Company, discriminated against her in violation of the federal Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq. (ADEA), and the Nebraska Act Prohibiting Unjust Discrimination Because of Age, Neb. Rev. Stat. §§ 48-1001 et seq., and Neb. Rev. Stat. § 20-148.Withers worked for Mutual Protective Insurance Company for twenty-three years.During the time relevant to this lawsuit, Withers was the administrative assistant to the president of Medico Life, William Busch. She also worked as the director of policy inquiries. When Busch became ill in 1996, he greatly reduced the number of hours he worked. In 1998, the company assigned Withers additional duties, processing life insurance claims, reporting to the Director of Claims Joe Koerner.Busch died on January11, 2001. On February23, 2001, Executive Vice-president Tim Hall notified Withers that the company was terminating her, effective February 28, 2001. Mutual Protective Insurance Company did not notify Withers of other administrative assistant positions open in the company. It did not rehire her when she applied for a vacant administrative assistant position in December 2001. All individuals hired to fill administrative positions after Withers’s termination were younger than Withers and no experience working for Mutual Protective Insurance Company. Mutual Protective Insurance Company claims that it had legitimate, non-discriminatory reasons for terminating Withers. The company claims to have undergone a reduction in force following Busch’s death, and Withers was discharged because most of her work for Busch had been personal in nature. The remaining work Withers performed could be assigned to other employees. The company did not offer Withers a transfer to other positions because either her qualifications did not match the position or she was too highly paid. The company also suggests that Withers had personality conflicts with other employees.INSTRUCTION NO. 12UNCONTROVERTED FACTSPursuant to the order on pretrial conference, the parties have stipulated to the following set of facts:1.Sally Withers is a citizen and resident of Omaha, Nebraska. She is 63 years of age, born February 19, 1940.2.The defendant Mutual Protective Insurance Company is a Nebraska corporation which sells health, life, and long-term care insurance policies throughout the United States.3.In May 1978, at age 38, Sally Withers was hired by Mutual Protective Insurance Company as a copy prep typist. In the following years, Withers received commendations and promotions, and eventually rose to the position of executive assistant to WiIlliam Busch, who was executive vi ce-president of Mutual Protective Insurance Company and was also president of Medico Life Insurance Company, a related business. In the early 1980s, Withers was assigned the task of handling complaints filed by State insurance departments, and was given the title of director of policy inquiries. In the early 1980s, Withers was appointed an assistant vice-president.4.In 1996, Busch became seriously ill and he significantly reduced his hours of work. As a result, in approximately 1998, Withers took on the additional duties of processing life insurance claims, reporting to Director of Claims Joe Koerner.5.Busch died on January 11, 2001.6.After Busch’s death, Withers continued to work, processing life insurance claims and handling complaints filed with state insurance departments.7.In January 2001, Nina Hunt, executive administrative assistant to Michael Murnane, an executive vice-president of Mutual Protective Insurance Company, transferred to another department, creating a vacancy for an administrative assistant.8.On February 11, 2001, Mutual Protective Insurance Company ran an ad in theOmaha World-Herald for an executive administrative assistant position.9.During the week of February 12-16, 2001, Mutual Protective InsuranceCompany interviewed several people for the position and offered the job toJulie Heeb, age 33. Mutual Protective Insurance Company did not interview or consider Withers for the position.10.On February 23, 2001, Withers was notified by Mutual Protective Insurance Company Executive Vice-President Tim Hall that she was being terminated effective February 28, 2001, with one month severance pay. On February 26,2001, Withers again spoke with Hall regarding the termination, but he stated thedecision was final. At the time of her termination, Withers was earning$3,686.00 per month. In December 2000, Withers had received a year-end bonus of $4,589.16, resulting in total salary plus bonus of $49,093 for the year2000.11.In mid-March 2001, Julie Heeb notified Mutual Protective Insurance Company that she would not start work as Michael Murnane’s administrative assistant, and the position became vacant. Withers was not considered for the position.12.On March 26, 2001, Withers filed an age discrimination charge with the Nebraska Equal Opportunity Commission and the federal Equal Employment Opportunity Commission.13.On April 2, 2001, Mutual Protective Insurance Company hired Tina Thompson, age 44, for the vacant administrative assistant position for Michael Murnane.14.On September 21, 2001, the Nebraska EqualOpportunity Commission issued a Determination of Reasonable Cause to believe that Withers had been discriminated against because of age. Withers has exhausted her administrative remedies and this lawsuit is appropriate for determination by the Court.15.Tina Thompson resigned in October 2001. Mutual Protective Insurance Company did not advertise for the position. Murnane contacted Mary Beth Francis, age 40, interviewed her, and offered her the vacant administrative assistant position. Withers was not considered for this position.16.Withers was out of work until January 8, 2003, when she began work atSedgwick Claims Company at a salary of $21,000 a year.TERMINATION: ESSENTIAL ELEMENTSYour verdict must be for the plaintiff and against the defendant on plaintiff's claim that she was discriminated against based upon her age in connection with her termination from employment with the defendant if both of the following elements have been proved by the greater weight of the evidence:1.The defendant terminated the plaintiff; and2.The plaintiff's age was a motivating factor in the defendant's decision. However, your verdict must be for defendant if either element has not been proved by the greater weight of the evidence, or if it has been proved by the greater weight of the evidence that defendant would have terminated plaintiff regardless of her age.FAILURE TO REHIRE: ESSENTIAL ELEMENTSYour verdict must be for the plaintiff and against the defendant on plaintiff's claim that she was discriminated against based upon her age in connection with the defendant’s failure to rehire the plaintiff if both of the following elements have been proved by the greater weight of the evidence:1.The defendant failed to rehire the plaintiff; and2.The plaintiff's age was a motivating factor in the defendant's decision. However, your verdict must be for defendant if either of these elements has not been proved by the greater weight of the evidence.TERMINATION: WILLFULNESSIf you find in favor of the plaintiff under Instruction No. 13, then you must decide whether the conduct of the defendant was "willful." You must find defendant's conduct was willful if you find by the greater weight of the evidence that, when the defendant terminated the plaintiff, the defendant knew the termination was in violation of the federal law prohibiting age discrimination, or that the defendant acted with reckless disregard of that law.FAILURE TO REHIRE: WILLFULNESSIf you find in favor of the plaintiff under Instruction No. 14, then you must decide whether the conduct of the defendant was "willful." You must find defendant's conduct was willful if you find by the greater weight of the evidence that, when the defendant failed to rehire the plaintiff, the defendant knew the failure to rehire was in violation of the federal law prohibiting age discrimination, or that the defendant acted with reckless disregard of that law.PRETEXTYou may find that plaintiff's age was a motivating factor in defendant's decisions to terminate and/or to not rehire the plaintiff if it has been proven by the greater weight of the evidence that defendant's stated reason for either of its decisions was not the true reason, but was a "pretext" to hide age discrimination.DEFINITION OF MOTIVATING FACTORAs used in these instructions, the plaintiff’s age was a "motivating factor," if the plaintiff’s age played a part in the defendant’s decision to terminate and/or not to rehire the plaintiff. However, the plaintiff’s age need not have been the only reason for the defendant’s decisions.INTRODUCTIONNow that you have heard the evidence and the attorneys’ arguments, it is my duty to inform you of the legal principles and considerations you are to use in arriving at a proper verdict.It is your duty to follow the law given you in this charge and to apply these rules of law to the facts as you find them from the evidence. Do not single out one instruction alone as stating the law, but consider the instructions as a whole.Do not be concerned with the wisdom of any rule of law that the court states. Regardless of any opinion you may have about what the law ought to be, it would violate your sworn duty to base a verdict upon a view of the law different from the one given in these instructions, just as it would violate your sworn duty as judges of the facts to base a verdict upon anything but the evidence in the case and the reasonable inferences arising from such evidence.JUDGE’S OPINIONIn the trial of this case and in these instructions, I have in no way attempted to express my opinion about who should prevail upon the issues submitted to you. You must not construe any statement, action, or ruling on my part during the trial as an indication of my opinion about the proper outcome of your verdict. During the course of a trial, I might have occasionally asked questions of a witness to bring out facts not fully covered in the testimony. Do not assume that I hold any opinion on the matters to which the questions related.EVIDENCE AND OBJECTIONSDuring the trial I have ruled on objections to certain evidence. You must not concern yourselves with the reason for such rulings since they are controlled by rules of law.You must not speculate or form or act upon any opinion about how a witness might have testified in answer to questions which I rejected during the trial, or upon any subject matter to which I forbade inquiry.In coming to any conclusion in this case, you must be governed by the evidence before you and by the evidence alone. You may not indulge in speculation, conjecture or inference not supported by the evidence.The evidence from which you are to find the facts consists of the following: (1) the testimony of the witnesses; (2) documents and other things received as exhibits; and (3) any facts that have been stipulated -- that is, formally agreed to by the parties.The following things are not evidence: (1) statements, comments, questions and arguments by lawyers for the parties; (2) questions by jurors; (3) objections to questions; (4) any testimony I told you to disregard; and (5) anything you may have seen or heard about this case outside the courtroom.REASONABLE INFERENCESWhile you should consider only the evidence in the case, you are permitted to draw such reasonable inferences from the testimony and exhibits as you feel are justified in the light of common experience. In other words, you may make deductions and reach conclusions which reason and common sense lead you to draw from the facts which have been established by the testimony and evidence in the case.ADEA: PROTECTED AGEUnder state and federal law, persons over the age of 40 are protected from discrimination because of their age. A person over 40 who is terminated and/or not rehired may be the victim of age discrimination even though the person actually selected is also 40 or over.ADEA: NEBRASKA EQUAL OPPORTUNITY COMMISSIONWhile the Nebraska Equal Opportunity Commission findings are relevant to the issues in this case, you should not consider those findings to be binding upon you. You must make your own determination based upon your review of all the evidence presented to you.TERMINATION: ACTUAL DAMAGESIf you find in favor of the plaintiff under Instruction No. 13, then you must award the plaintiff such sum as you find by the greater weight of the evidence will fairly and justly compensate the plaintiff for any wages and fringe benefits you find the plaintiff would have earned in her employment with the defendant if she had not been terminated on February23, 2001, minus the amount of earnings and benefits from other employment received by the plaintiff during that time.Remember that throughout your deliberations, you must not engage in anyspeculation, guess, or conjecture, and you must not award damages under this Instruction through sympathy.FAILURE TO REHIRE: ACTUAL DAMAGESIf you find in favor of the plaintiff under Instruction No. 14, then you must award the plaintiff such sum as you find by the greater weight of the evidence will fairly and justly compensate the plaintiff for any wages and fringe benefits you find the plaintiff would have earned in her employment with the defendant if she had been rehired by the defendant on or about April 1, 2991, October 8, 2001, or January 2, 2002, minus the amount of earnings and benefits from other employment received by the plaintiff during that time.Remember that throughout your deliberations, you must not engage in any speculation, guess, or conjecture, and you must not award damages under this Instruction through sympathy.ADEA: NO PUNITIVE OR EXEMPLARY DAMAGESIf you determine that the plaintiff Sally Withers is entitled to damages, in determining the amount of damages you may not include or add to the damages any sum for the purpose of punishing defendant Mutual Protective Insurance Company or serving as an example to warn others.ADEA: LEGITIMATE BUSINESS REASONSThe ADEA is not a vehicle for review of employment decisions which are made in good faith and are not motivated by age discrimination. An employer may develop its own policies and criteria for deciding whom to employ and what to pay an employee in the absence of an intent to discriminate. Thus, if you find that Mutual Protective Insurance Company’s reasons for terminating Sally Withers and not rehiring her were based on reasons in which her age was not a motivating factor, then the termination and failure to rehire were not unlawful. You are not to consider whether Mutual Protective Insurance Company’s decisions to terminate Withers and to not rehire her were fair, wise, or even correct, or whether you or anyone else would have made the same decision. The solefocus of your consideration must be on Mutual Protective Insurance Company’s motivation. This relates to the court’s instructions on essential elements (Instruction Nos. 13 and 14), willfulness (Instruction Nos. 15 and 16), pretext (Instruction No. 17), and motivating factors (Instruction No. 18). However, do not single out any one instruction alone as stating the law, but consider the instructions as a whole.NOTE-TAKINGThroughout the course of the trial you have been allowed to take notes of the testimony. You may take your notes into the jury room for use in your deliberations. Remember, however, your notes are not evidence. The courtroom deputy is charged with the task of keeping the official record of all exhibits received into evidence during the trial. At the close of trial, she will deliver all exhibits you are to consider in your deliberations.Your notes should be used only as aids to your memory. You should not give your notes precedence over your independent recollection of the evidence. You should rely on your own independent recollection of the proceedings, and you should not be influenced by the notes of other jurors. Your notes are not entitled to any greater weight than each juror’s recollection or impression of the testimony given during this trial. After you have reached a verdict, your notes will be destroyed.DEPOSITION TESTIMONYDuring the trial of this case, certain testimony will be presented to you by way of deposition, consisting of sworn recorded answers to questions asked of the witness in advance of the trial by one or more of the attorneys for the parties to the case. The testimony of a witness who, for some reason, cannot be present to testify from the witness stand may be presented in writing under oath. Such testimony is entitled to the same consideration, and is to be judged as to credibility, and weighed, and otherwise considered by the jury, insofar as possible, in the same way as if the witness had been present, and had testified from the witness stand.DELIBERATIONS AND VERDICTIn conducting your deliberations and returning your verdict, there are certain rules you must follow.First, when you retire to the jury room, first select one of your number to be foreperson to preside over your discussions and to speak for you here in court.Second, it is your duty, as jurors, to discuss this case with one another in the jury room. You should try to reach agreement because a verdict—whether liable or not liable—must be unanimous. Each of you must make your own conscientious decision, but only after you have considered all the evidence, discussed it fully with your fellow jurors, and listened to the views of your fellow jurors. Do not be afraid to change your opinions if the discussion persuades you that you should. But do not come to a decision simply because other jurors think it is right, or simply to reach a verdict.Third, you will take with you when you retire for your deliberations an official verdict form on which you will indicate a verdict. Please follow the directions carefully when filling it out. A verdict must be agreed to by all of you, that is, it must be unanimous. Your verdict must be signed by the foreperson.Fourth, if you need to communicate with me during your deliberations, you maysend a note to me through the courtroom deputy, signed by one or more jurors. I will respond as soon as possible either in writing or orally in open court. Your answer may not come immediately because I may need to assemble the attorneys and confer with them before I respond. Remember that you should not tell anyone—including me—how your votes stand numerically.Finally, when you arrive at your verdict and the form of verdict has been completed, you will have concluded your task. Notify my chambers and I will receive your verdict promptly. If you do not agree on a verdict by 5:00 this evening, you may separate and return for further deliberations tomorrow morning. You may separate for meals wheneveryou choose. If you do separate, you are not allowed to discuss this case with anyone, even another juror. ................
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