3d Cir. Model Jury Instr. (Criminal) 4.19

Related Offense, Accomplices, Immunized Witnesses, Cooperating Witnesses

You have heard evidence that (name of witness) [Include as many of the

following that apply:

is an alleged (accomplice)(co-conspirator), someone who says

(he)(she) participated in the crime charged; or

has made a plea agreement with the government; or

has received a promise from the government that (he)(she) will not

be prosecuted; or

has received a promise from the government that (his)(her)

testimony will not be used against (him)(her) in a criminal case; or

received a benefit from the government in exchange for testifying.]

(His)(Her) testimony was received in evidence and may be considered

by you. The government is permitted to present the testimony of someone

who has (describe the witness’s situation, e.g., reached a plea bargain with the

government, received a benefit from the government) in exchange for (his)(her)

testimony, but you should consider the testimony of (name of witness) with

great care and caution. In evaluating (name of witness)’s testimony, you

should consider this factor along with the others I have called to your

attention. Whether or not (his)(her) testimony may have been influenced by

the (plea agreement)(government's promise)(alleged involvement in the crime

charged) is for you to determine. You may give (his)(her) testimony such

weight as you think it deserves.

[You must not consider (name of witness)’s guilty plea as any evidence of

(name of defendant)’s guilt. (His)(her) decision to plead guilty was a personal

decision about (his)(her) own guilt. Such evidence is offered only to allow you to

assess the credibility of the witness; to eliminate any concern that (the defendant)

(any of the defendants) has been singled out for prosecution; and to explain how

the witness came to possess detailed first-hand knowledge of the events about

which (he)(she) testified. You may consider (name of witness)’s guilty plea only

for these purposes.]