301.1 Deposition, Testimony, Interrogatories, Stipulated Testimony, Stipulations, and Admissions (From 1.13(a)) a. Deposition or prior testimony: Members of the jury, the sworn testimony of (name), given before trial, will now be presented. You are to consider and weigh this testimony as you would any other evidence in the case. b. Interrogatories: Members of the jury, answers to interrogatories will now be read to you. Interrogatories are written questions that have been presented before trial by one party to another. They are answered under oath. You are to consider and weigh these questions and answers as you would any other evidence in the case. c. Stipulated testimony: Members of the jury, the parties have agreed that if (name of witness) were called as a witness, [he] [she] would testify (read or describe the testimony). You are to consider and weigh this testimony as you would any other evidence in the case. d. Stipulations: Members of the jury, the parties have agreed to certain facts. You must accept these facts as true. (Read the agreed facts.) e. Admissions: 1. Applicable to all parties: Members of the jury, (identify the party or parties that have admitted the facts) [has] [have] admitted certain facts. You must accept these facts as true. (Read the admissions.) 2. Applicable to fewer than all parties: Members of the jury, (identify the party or parties that have admitted the facts) [has] [have] admitted certain facts. You must accept these facts as true in deciding the issues between (identify the affected parties), but these facts should not be used in deciding the issues between (identify the unaffected parties). (Read the admissions.)