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US-CA3 · jury_instructions

3d Cir. Model Jury Instr. (Criminal) 4.16

Missing Witness

activein force · 2026-08-19 – presentas-observed

You have heard evidence about (name of missing witness), who has not

been called to testify. The defense has argued that (name of missing witness)’s

testimony could have been important to this case and that (name of missing

witness) was available as a witness only to the government and not to the

defense.

If you find that the government could have called (name of missing

witness) as a witness and that (name of missing witness) would have given

important new testimony, and you also find that (name of missing witness) was

available as a witness only to the government and not to the defense and that

the government failed to call (name of missing witness), you are permitted, but

you are not required, to infer that (name of missing witness)’s testimony would

have been unfavorable to the government.

You must decide whether you believe that (name of missing witness)

would have testified unfavorably to the government. You should not draw

such a conclusion if the witness was equally available to both parties or if the

witness’s testimony would have merely repeated the testimony of other

witnesses or evidence already presented in the case.

Provenance

Source
ca3.uscourts.gov
Retrieved
2026-08-19
Edition
2026-08-19
Content hash
2e480c1adb790dbb2c5b546ec4b2991082e1ecd7ea27fb4cab9da7f915cef6ad
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