215. Exercise of a Communication Privilege Instruction No 1 Request by Plaintiff Request by Defendant Requested by Given as Proposed Given as Modified Given on Court?s Motion Refused Withdrawn Judge Instruction No 1 [Name of party/witness] has an absolute right not to disclose what [he/she] told their [doctor/attorney/[other]] in confidence because the law considers this information privileged. Do not consider, for any reason at all, the fact that [name of party/witness] did not disclose what [he/she] told [his/her] [doctor/attorney/[other]]. Do not discuss that fact during your deliberations or let it influence your decision in any way. New September 2003; Revised December 2012