8. Jury Instructions, Voir Dire Questions, and Special Verdict
Forms
U.S. District Court of Maryland Local Rules (December 1, 2025)
numerous exhibits, counsel shall be prepared to discuss proposals for the orderly
presentation of the exhibits at trial.
7. Pretrial Preparation of Exhibits
a) Pretrial Numbering
Prior to trial, counsel shall attach tags to all exhibits clearly identifying their proponent
and number. Tags may be obtained from the Clerk. Counsel shall file with the Clerk and
serve upon opposing counsel at least one (1) business day prior to the scheduled trial date an
exhibit list. Counsel shall retain the exhibits until they are presented at trial. This Rule does
not apply to exhibits to be used solely for impeachment.
b) Pretrial Review of Exhibits
Prior to trial, counsel shall meet for the purpose of reviewing and making available for
copying one another’s proposed exhibits, except those to be used solely for impeachment.
All exhibits which are proffered at trial shall be precisely the same in form and substance as
the exhibits which were made available for review and copying prior to trial unless counsel
otherwise indicates to opposing counsel.
8. Jury Instructions, Voir Dire Questions, and Special Verdict Forms
a) Submission Procedure
i) Cases Subject to Electronic Filing. Unless otherwise ordered, proposed jury
instructions, voir dire questions, and special verdict forms should be filed electronically.
ii) Cases Exempt from Electronic Filing. Unless otherwise ordered, the original and
two (2) copies of proposed instructions, voir dire questions, and special verdict forms shall
be filed with the Clerk.
b) Contents of Proposed Instructions
Proposed instructions shall be numbered and shall set forth in a separate paragraph or
on a separate page a citation to any authorities upon which they are based. Counsel may
submit any proposed instructions which they deem appropriate, but unless otherwise
ordered by the Court, counsel need not submit proposed instructions on general matters not
particular to the case. Upon request, the Court shall provide to counsel a copy of its
customary general instructions prior to the instructions submission deadline.
