Medical Malpractice: Sample Jury Instructions

IN THE CIRCUIT COURT FOR BALTIMORE COUNTY, MARYLAND

MANDY BADWELL,
Plaintiff,
v.
THOMAS B. ANTHONY, et al.,
Defendants.

Case No.: 20-C-05-005540

PLAINTIFF’S JURY INSTRUCTIONS

Plaintiff, Mandy Badwell, by and through her attorneys, Ronald V. Miller, Jr., Rodney M. Gaston and Miller & Zois, LLC, requests that the Court present the jury with the following instructions:

1. 1.1 INTRODUCTION
2. 1.2 QUESTIONS OF LAW DURING THE TRIAL
3. 1.3 WITNESS TESTIMONY DURING TRIAL
4. 1.6 INFERENCES FROM STATEMENTS MADE BY THE COURT
5. 1.7 BURDEN OF PROOF-PREPONDERANCE OF THE EVIDENCE
6. 1.13 UNANIMOUS VERDICT
7. DE 6.1A DEFINITION OF MEDICAL NEGLIGENCE
8. DE 10.1 PROXIMATE CAUSE
9. DE 6.3 AGENCY OF TREATING DOCTORS AND NURSES
10. DE 10.4 PLAINTIFF SUSCEPTIBLE TO INJURY
11. 10.26 LIFE EXPECTANCY
12. DE 21.1 DAMAGES – PERSONAL INJURY

Miller & Zois, LLC

Rodney M. Gaston
1 South St, #2450
Baltimore, MD 21202
(410)779-4600
(410)760-8922 (facsimile)
Attorney for Plaintiff

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client-reviews
Client Reviews
★★★★★
They quite literally worked as hard as if not harder than the doctors to save our lives. Terry Waldron
★★★★★
Ron helped me find a clear path that ended with my foot healing and a settlement that was much more than I hope for. Aaron Johnson
★★★★★
Hopefully I won't need it again but if I do, I have definitely found my lawyer for life and I would definitely recommend this office to anyone! Bridget Stevens
★★★★★
The last case I referred to them settled for $1.2 million. John Selinger
★★★★★
I am so grateful that I was lucky to pick Miller & Zois. Maggie Lauer
★★★★★
The entire team from the intake Samantha to the lawyer himself (Ron Miller) has been really approachable. Suzette Allen
★★★★★
The case settled and I got a lot more money than I expected. Ron even fought to reduce how much I owed in medical bills so I could get an even larger settlement. Nchedo Idahosa
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