To prove that the defendant is guilty of this crime, the People must prove that:

1.      The defendant (committed a crime that posed a high risk of death or great bodily injury because of the way in which it was committed/ [or] committed a lawful act, but acted with criminal negligence);

AND

2.      The defendant’s acts caused the death of another person.

[The People allege that the defendant committed the following crime[s]:             <insert misdemeanor[s]/infraction[s])/
noninherently dangerous (felony/felonies)>.

Instruction[s] ______________  tell[s] you what the People must prove

in order to prove that the defendant committed  <insert misdemeanor[s]/infraction[s])/ noninherently dangerous (felony/felonies)>.]

[The People [also] allege that the defendant committed the following lawful act[s] with criminal negligence: ___________________________________________
<insert act[s] alleged>.]

[Criminal negligence involves more than ordinary carelessness, inattention, or mistake in judgment. A person acts with criminal negligence when:

1.      He or she acts in a reckless way that creates a high risk of death or great bodily injury;

AND

2.      A reasonable person would have known that acting in that way would create such a risk.

In other words, a person acts with criminal negligence when the way he or she acts is so different from the way an ordinarily careful person would act in the same situation that his or her act