PG II(F) Identifying The Party Who Has The Burden Of Proof.
It is error to instruct the jury regarding proof of a fact without identifying the party bearing the burden and the standard of proof. (EC 502; People v. Simon (95) 9 C4th 493, 500-01 [37 CR2d 278] [as to defense theories, the trial court is required to instruct on who has the burden and the nature of that burden]; U.S. v. Solano (9th Cir. 1993) 10 F3d 682, 683.)
[See also FORECITE BIBLIO, “Language/Drafting of Instructions” (BIBLIO L)]