This is a criminal case brought by the United States government. A defendant has the right to remain silent and never has to prove innocence or present any evidence. The description of the offense given in this introduction instruction should not track statutory language but should be stated in plain language, avoiding the technical and repetitive language of the statute. Before giving the jury an elements instruction, counsel should be consulted. The duty to make objections and the effect of rulings on objections are the subject of a separate instruction.
Some evidence is admitted for a limited purpose only.
When I instruct you that an item of evidence has been admitted for a limited purpose, you must consider it only for that limited purpose and for no other. As a general rule, limiting instructions need only be given when requested and need not be given sua sponte by the court. Direct evidence is direct proof of a fact, such as testimony by a witness about what that witness personally saw or heard or did. Circumstantial evidence is indirect evidence, that is, it is proof of one or more facts from which one can find another fact. You are to consider both direct and circumstantial evidence.