To prove this allegation, the People must prove that:

1.    (The defendant/__________ <insert name or description of
principal if not defendant>) killed a person by shooting a firearm from a motor vehicle;

2.    (The defendant/__________ <insert name or description of
principal if not defendant>) intentionally shot at a person who was outside the vehicle;

AND

3.    When (the defendant/___ <insert name or
description of principal if not defendant>) shot a firearm, (the defendant/      <insert name or description of
principal if not defendant>) intended to inflict great bodily injury on the person outside the vehicle.

[A firearm is any device designed to be used as a weapon, from which a projectile is discharged or expelled through a barrel by the force of an explosion or other form of combustion.]

[A motor vehicle includes (a/an) (passenger

vehicle/motorcycle/motor scooter/bus/school bus/commercial vehicle/truck tractor and trailer/ <insert other type of
motor vehicle>).]

[Great bodily injury means significant or substantial physical injury. It is an injury that is greater than minor or moderate harm.]

[The term[s] (great bodily injury[,]/ firearm[,]/ [and] motor vehicle) (is/are) defined in another instruction to which you should refer.]

[The People must prove that the defendant intended that the person shot at suffer great bodily injury when (he/she/
______________ <insert name or description ofprincipal if not
defendant>) shot from the vehicle. However, the People do not have