There are in evidence photographs that were used to
identify the defendant in this case.
With reference to the photographs submitted into
evidence, you will notice that many or all of the photographs appeared to have
been taken by a law enforcement agency, or some other government entity.
You are not to consider the fact that the agency obtained
a photograph of the defendant as prejudicing him/her in any way. The
photographs are not evidence that the defendant has ever been arrested or
convicted of any crime. Such photographs
come into the hands of law enforcement from a variety of sources, including but
not limited to driver's license applications, passports, ABC identification
cards, various forms of government employment, private employment requiring
state regulation, including but not limited to casino license applications,
security guard applications, etc., or from a variety of other sources totally
unconnected with criminal activity.