njcourts.gov
CHARGE 1.18 Page 1 of 4 1.18 WITNESS — FAILURE OF A PARTY TO PRODUCE ; ADVERSE INFERENCE (Approved 05/1970; Revised 10/2016) NOTE TO JUDGE Before charging the jury as to adverse inference, the party seeking the charge must, before the parties rest, notify …
njcourts.gov
Charge 1.19 — Page 1 of 6 1.19 BURDEN OF PROOF — CLEAR AND CONVINCING EVIDENCE (Approved 4/1988; Revised 8/2011) With regard to (state here the factual issue(s) to be proved) it is the obligation of (state here the party or parties upon whom the burden of …
njcourts.gov
Charge 1.20 Charge 1.20 — Page 1 of 4 1.20 SUPPLEMENTAL INSTRUCTIONS AS TO FURTHER DELIBERATIONS BY JURY (Approved 4/96) You have informed me that you have been unable as a jury to reach a verdict in this case. I do not wish to know, and I direct each of …
njcourts.gov
CHARGE 2.21 — Page 1 of 13 2.21 THE NEW JERSEY LAW AGAINST DISCRIMINATION (“NJLAD”) ( N.J.S.A. 10:5-1 et seq .) Introductory Note TO THE COURT (Approved 5/03) The model employment discrimination charges that follow comprise a suggested framework for the …
njcourts.gov
Charge 1.22 Charge 1.22 — Page 4 of 4 1.22 EXPEDITED JURY TRIALS (Approved 01/2001) (PRELIMINARY and POST TRIAL INSTRUCTIONS) NOTE TO JUDGE An “expedited jury trial” is a form of “summary jury trial” conducted pursuant to a consent order, which results in …
njcourts.gov
Charge 1.23 Charge 1.23 — Page 2 of 2 1.23 PRELIMINARY INSTRUCTIONS REGARDING JUROR’S QUESTIONS (Approved 9/02) In this trial, after the lawyers have asked their own questions of each witness, I will give you an opportunity to write out any additional …
njcourts.gov
Charge 1.24 Charge 1.24 - Page 1 of 1 1.24 FINAL INSTRUCTIONS REGARDING JURORS’ QUESTIONS (Approved 9/02) In this trial, I allowed you to submit certain questions that you wanted the witnesses to answer. Some were in fact asked and answered, and others …
njcourts.gov
Charge 1.24 Charge 1.25 - Page 1 of 1 1.25 OPTIONAL CHARGE CONCERNING VIDEO RECORDED TESTIMONY (04/2016) Members of the Jury, under certain circumstances, a party to a lawsuit has the right to present testimony through the use of a video recorded …
njcourts.gov
CHARGE 2.11 — Page 4 of 4 2.11 WRONGFUL DISCHARGE IN VIOLATION OF A CLEAR MANDATE OF PUBLIC POLICY (Approved 3/91; Revised 7/10) Plaintiff has alleged that he/she was wrongfully discharged from his/her position in violation of public policy. I charge you …
njcourts.gov
Charge 2.12 — Page 10 of 15 2.12 PERSONNEL MANUAL CREATING A CONTRACT (Approved 1/97) Plaintiff has asserted a claim against defendant for breach of an employment contract. Plaintiff’s claim is not based upon an individual contract he/she had with …
njcourts.gov
Charge 2.13 Charge 2.13 — Page 2 of 2 2.13 ORAL PROMISES CREATING AN ENFORCEABLE CONTRACT1 (Approved 3/91) Plaintiff has brought this case against his/her employer for breach of an oral contract of employment. Plaintiff claims that defendant’s oral …
njcourts.gov
Charge 2.14 Charge 2.14 — Page 3 of 4 2.14 EXCEPTIONS TO THE EMPLOYEMENT-AT-WILL DOCTRINE: UNWRITTEN PERSONNEL POLICY REGARDING TERMINATION OF EMPLOYMENT (Approved 12/01) NOTE TO JUDGE To be provided in conjunction with, or following, general instructions …
njcourts.gov
CHARGE 2.15 — Page 6 of 6 2.15 GOOD FAITH AND FAIR DEALING (9/09) The plaintiff in this case contends that he/she had an employment contract with the defendant and that the defendant breached what is known as the implied covenant of good faith and fair …
njcourts.gov
Charge 2.34 CHARGE 2.16 — Page 10 of 10 2.16 DEFAMATION AND EMPLOYMENT (Approved 6/95) NOTE TO JUDGE This charge is to be used only where defamation involves private figures claiming to have been defamed. A. General Elements of Defamation In this lawsuit, …
njcourts.gov
CHARGE 2.22 — Page 9 of 9 2.22 UNLAWFUL EMPLOYMENT PRACTICES UNDER THE NEW JERSEY LAW AGAINST DISCRIMINATION (LAD) — RETALIATION ( N.J.S.A. 10:5-12(d) and -12(r)) (Approved 09/2009; Revised 01/2019) NOTE TO JUDGE The Law Against Discrimination (LAD) has …
njcourts.gov
CHARGE 2.22A — Page 2 of 2 2.22A LAW AGAINST DISCRIMINATION (LAD) INDIVIDUAL LIABILITY CLAIMS (Approved 3/10) If you find that defendant [employer] has unlawfully discriminated [and/or retaliated] against plaintiff, you must then consider whether …
njcourts.gov
CHARGE 2.23 — Page 1 of 1 2.23 Discriminatory Layoff or Reduction in Force (RIF) (Approved 5/91) Plaintiff has contended that the layoff or reduction in force at [employer's name] was conducted in a discriminatory manner. In order to establish an initial …
njcourts.gov
CHARGE 2.24A — Page 6 of 13 2.24A NEW JERSEY equal pay ACT (Approved 03/2019; revised 11/2019) NOTE TO JUDGE This charge is intended for claims of unequal pay brought under the Diane B. Allen Equal Pay Act (New Jersey Equal Pay Act), N.J.S.A. 10:5-12(t), …
njcourts.gov
CHARGE 2.24B — Page 2 of 3 2.24B Wage Disparity Under the NJLAD[footnoteRef:1] (Approved 05/1991; Revised 11/2019) [1: This charge was previously designated as 2.24. In 2018, the New Jersey Legislature passed the Diane B. Allen Equal Pay Act (“NJEPA”), …
njcourts.gov
CHARGE 2.25 - Page 22 of 22 2.25 HOSTILE WORK ENVIRONMENT CLAIMS UNDER THE NEW JERSEY LAW AGAINST DISCRIMINATION (SEXUAL AND OTHER HARASSMENT) (Approved 05/2015; Revised 01/2025) NOTE TO JUDGE The following charge is based on the Supreme Court’s decision …