Local Civil Rule 51
                     INSTRUCTIONS TO JURY AND DELIBERATION


   (a) Proposed.

   (1)Instructions Required of Plaintiff.  Plaintiff's counsel shall prepare
and present to the Court a cover instruction containing the title and file
number of proceedings, the name of the attorney for each party properly
designated, and appropriate blank space where the name of the judge hearing the
case can be inserted, and entitled "Instructions of the Court."

   (2) Instructions in the Alternative.  Instructions, the form of which are
dependent upon rulings of the Court, may be submitted in the alternative and
counsel shall have the right to withdraw those instructions made unnecessary or
inappropriate by reason of said rulings at any time prior to the submission of
the Court's instructions to the jury.

   (b) Submission.

   (1) Distribution.  Sets of proposed instructions shall be prepared and
distributed as follows:

   (A) Original, which shall be assembled and numbered and contain citations,
shall be filed with the clerk;

   (B) One copy, which shall be assembled, numbered and contain citations,
shall be provided to counsel for each other party;

   (C) One copy, which shall be assembled and numbered, shall be retained by
the counsel preparing them;

   (D)  One copy, which shall be assembled, numbered and contain citations, shall
be provided to the trial judge;

   (E)  One copy, without numbers or citations, shall be provided to the trial judge.

   (F)  Citations, as required by the rule, shall include applicable WPI or WPIC
numbers and shall appear on the bottom of the proposed instructions.

   (2) Time for Serving Instructions.  Unless requested earlier by the trial
judge, all instructions, shall be submitted at the beginning of the first day
of trial.  Upon request of the trial judge to all counsel and made not more
than seven (7) days before the date of trial, counsel shall prepare and deliver
to the trial judge and to other counsel, not less than three (3) days before
the day on which the case is set for trial, the required number of copies of
proposed instructions insofar as counsel may then be able to determine them.

   (c) Verdict Forms.  Each verdict form shall be headed with title and cause
number of the proceeding.  This shall also apply to special interrogatories.  A
date line shall be typed above the line for the foreman.

   (d) Published Instructions.

   (1) Request.  The Court has not adopted a local rule to allow instructions
appearing in the Washington Pattern Instructions (WPI or WPIC) to be requested
by reference to the published number.

   (2) Modified Instructions.  Whenever a Washington Pattern Instruction (WPI
or WPIC) is modified by the addition of, the deletion of, or the modification
of certain language, the party proposing the instruction must cite the
instruction as follows: "WPI or WPIC No. Modified."

   (e) Disregarding Requests.   The trial court may disregard any proposed
instruction not proposed or submitted in accordance with this rule.

   (f) Civil and Criminal.  This rule applies to instructions for civil and
criminal cases.

   (g) Duties Relating to Return of Verdict.  Attorneys awaiting a verdict
shall keep the clerk advised of where they may be reached by phone.  Attorneys
desiring to be present for the verdict shall be at the courthouse within
fifteen (15) minutes of the time they are called.  In a criminal case, at least
one attorney for each party and the prosecuting attorney or deputy prosecuting
attorney shall be present for the receipt of the verdict, unless excused by the
Court.  The defense attorney is responsible for advising the defendant to be
present for the verdict unless defendant is in custody.


[Adopted effective April 1, 1986; Amended effective September 1, 2003;
September 1, 2005, September 1, 2009. September 1, 2011]