I'm a big believer in the idea that you should start writing your jury instructions long before trial. It helps identify the theme and theory of your defense. It directs you where to focus both your opening statement and closing argument. With more time, you are less likely to adopt a standard instruction, which - as I've indicated elsewhere (kidnapping | Safewords | Threats) - should be looked upon with a great deal of skepticism. And if you don't get the special instructions you want,that denial dramatically improves your chances of success on appeal. Most of all, jury instructions can help frame the issue for the jury in a way that will make an appeal moot. This outline largely consists of the basics: everything in it will be familiar to the experienced lawyer, but I personally find anything that can refresh what I once knew to be increasingly valuable. And maybe the stuff inside will help you persuade the judge why your requested instruction is essential to a fair and just trial.