Author: Jay Young

Nevada Jury Instructions CREDIBILITY OF WITNESS; WITNESS WHO HAS TESTIFIED FALSELY The credibility or “believability” of a witness should be determined by his or her manner upon the stand, his or her relationship to the parties, his or her fears, motives, interests or feelings, his or her opportunity to have observed the matter to which…

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Nevada Jury Instructions STIPULATIONS AS EVIDENCE If counsel for the parties have stipulated to any fact, you will regard that fact as being conclusively proved [as to the party or parties making the stipulation]. NEV. J.I. 2.06 BAJI 1.02 Jay YoungHon. Jay Young (Ret.) is a retired judicial officer with decades of experience presiding over…

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Nevada Jury Instructions RESPONSES TO REQUESTS FOR ADMISSIONS AS EVIDENCE In this case, as permitted by law, the [plaintiff] [defendant] served on the [defendant] [plaintiff] a written request for the admission of the truth of certain matters of fact. You will regard as being conclusively proved all such matters of fact which were expressly admitted…

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Nevada Jury Instructions ANSWERS TO INTERROGATORIES AS EVIDENCE During the course of the trial you have heard reference made to the word “interrogatory”. An interrogatory is a written question asked by one party of another, who must answer it under oath in writing. You are to consider interrogatories and the answers thereto the same as…

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Nevada Jury Instructions WHEN THIRD PARTY’S INTERVENING NEGLIGENCE IS NOT A SUPERSEDING CAUSE If you find that defendant [(first actor)] was negligent and that his negligence was a substantial factor in bringing about an injury to the plaintiff but that the immediate cause of the injury was the negligent conduct of [ a third person]…

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Nevada Jury Instructions CONCURRING CASES There may be more than one [proximate] [legal] cause of an injury. When negligent conduct of two or more persons contributes concurrently as [proximate] [legal] causes of an injury, the conduct of each of said persons is a [proximate] [legal] cause of the injury regardless of the extent to which…

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Nevada Jury Instructions RES IPSA LOQUITUR; PERMISSIBLE INFERENCE OF NEGLIGENCE From the happening of the [accident] [injury] involved in this case, you may draw an inference that a [proximate] [legal] cause of the occurrence was some negligent conduct on the part of the defendant. However, you shall not find that [proximate] [legal] cause of the…

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Nevada Jury Instructions RES IPSA LOQUITUR; NECESSARY CONDITIONS FOR APPLICATION On the issue of negligence, one of the questions for you to decide in this case is whether the [accident] [injury] occurred under the following conditions: First, that it is the kind of [accident] [injury] which ordinarily does not occur in the absence of someone’s…

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Nevada Jury Instructions LEGAL CAUSE; DEFINITION A legal cause of injury, damage, loss or harm is a cause which is a substantial factor in bringing about the injury, damage, loss, or harm. NEV. J.I. 4.04A BAJI 3.76 Jay YoungHon. Jay Young (Ret.) is a retired judicial officer with decades of experience presiding over complex civil…

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