Fla. Std. Jury Instr. (Crim.) 3.7

The defendant has entered a plea of not guilty. This means you must presume or believe the defendant is innocent. The presumption stays with the defendant as to each material allegation in the [information] [indictment] through each stage of the trial unless it has been overcome by the evidence to the exclusion of and beyond a reasonable doubt.

To overcome the defendant's presumption of innocence, the State has the burden of proving the crime with which the defendant is charged was committed and the defendant is the person who committed the crime.

The bracketed part of the paragraph below should be given only when the defendant is relying on an affirmative defense for which he or she has the burden of persuasion (e.g., insanity, renunciation of an attempt).

The defendant is not required to present evidence or prove anything [except for the defense of (insert relevant affirmative defense) to the crime[s] of (insert relevant crime[s]) as I previously explained to you].

Whenever the words “reasonable doubt” are used, you must consider the following:

Reasonable doubt is not proof beyond all doubt. A mere possible, speculative, imaginary, or forced doubt is not a reasonable doubt. Such a doubt is not a guess or mere conjecture.

Rather, it is a doubt based upon reasoning and common sense after careful and impartial consideration of all the evidence in the case.

A reasonable doubt as to the guilt of the defendant may arise from the evidence, conflict in the evidence, or the lack of evidence. If after a careful and impartial consideration of all the evidence, you have a reasonable doubt as to the guilt of the accused, it is your duty to find the defendant not guilty. On the other hand, if after a careful and impartial consideration of all the evidence, you are convinced beyond a reasonable doubt that the defendant is guilty, it is your duty to find the defendant guilty.

It is to the evidence introduced in this trial, and to it alone, that you are to look for that proof.