You have been selected and sworn as the jury to try the case of the State of Oklahoma against [Name the Defendant(s)]. The defendant(s) is/are charged with the crime(s) of [Name the Crime Charged] by an information/indictment filed by the State.
The information/indictment in this case is the formal method of accusing the defendant(s) of [a] crime(s). The information/indictment is not evidence and the law is that you should not allow yourselves to be influenced against the defendant(s) by reason of the filing of the information/indictment.
The defendant(s) has/have pled not guilty. A plea of not guilty puts in issue each element of the crime with which the defendant(s) is/are charged. A plea of not guilty requires the State to prove each element of the crime beyond a reasonable doubt.
The defendant(s) is/are presumed innocent of the crime(s) and the presumption continues unless after consideration of all the evidence you are convinced of his/her guilt beyond a reasonable doubt. The State has the burden of presenting the evidence that establishes guilt beyond a reasonable doubt. The defendant must be found not guilty unless the State produces evidence which convinces you beyond a reasonable doubt of each element of the crime(s).
Evidence is the testimony received from the witness(es) under oath, agreements as to fact made by the attorneys, and the exhibits admitted into evidence during the trial.
It is your responsibility as jurors to determine the facts from the evidence, to follow the law as stated in the instructions from the judge, and to reach a verdict of not guilty or guilty based upon the evidence [and to determine punishment if you should find the defendant(s) guilty].
Notes on Use
The immediately preceding bracketed clause should be used only in a non-bifurcated trial.