Every judge in New Hampshire has his or her own preferred instructions. It’s not an easy feat to convince a judge your way is better. That’s why I suggest, as you’ll see in the example, that you separate your instructions so that it’s simple for the judge to add or subtract as convinced. Each instruction, on each point, has its own page making its inse1tion simple. This also makes it easier when working with opposing counsel.
Also, you’ll note the instructions are personalized. No - defendant and plaintiff. I use real names. I’ve minimized legal speak as well. Real people, like jurors, like real words.