Conn. Civ. Jury Instr. 2.5-7

You will recall that <insert name of witness/deponent> was called to testify as a

(witness/deponent) in this case, but <insert name of witness> declined to respond to questions

concerning <insert putative conduct>. As you probably know, under our laws, no person can be

compelled to testify about matters that tend to demonstrate that the person engaged in criminal

behavior.

In a civil case such as this, however, the refusal of a (witness/deponent) to testify based on this

privilege allows jurors to draw an adverse inference. That is, you may infer that the

(witness/deponent) did, indeed, engage in the criminal conduct about which the

(witness/deponent) chooses to remain silent. In other words, that silence can be regarded as a

tacit admission that the (witness/deponent) engaged in <insert putative conduct>.

Now, you are not required to draw this adverse inference, but you may do so if you find the

inference to be logical and reasonable in light of all the evidence in the case. It is solely within

your province to determine whether to draw the inference of guilt and what role that evidence

plays in your ultimate decisions in this case.