CR04-061                   01/10/05




            (Def)_______________ is presumed to be innocent of the charge[s].  This is called the “presumption of innocence.”  Although accused, (Def)_______________ is innocent at the beginning of the trial.  This presumption of innocence stays with [him] [her] throughout the trial and during your deliberations.  The presumption is itself a piece of evidence which you should consider in (Def)_______________’s favor in deciding this case.  The presumption of innocence means that you must find (Def)_______________ not guilty unless, after careful and impartial consideration of all the evidence, you are satisfied beyond a reasonable doubt that [he] [she] is guilty.