In a prior post, 2/20/09 Post, I noted that a Central District Court Judge in Stoltie questioned the Ninth Circuit's Model Reasonable Doubt Instruction. I suggested attorneys object to the model instrution and proposed Judge Karlton's standard instruction as an alternative. 2/25/09 Post. Last week, Judge Wanger in Fresno became the second EDCA district judge I am aware of to modify the Ninth Circuit's standard instruction. He did so by including additional language that a reasonable doubt may be based on reason, common sense, or "any matter that leads you to question the truth of the charge." See RD Jury Instruction, 08-224-OWW. A better formulation than the Ninth Circuit's model instruction in my view.