The defendant is charged [in Count ___________  ] with attempted murder.

To prove that the defendant is guilty of attempted murder, the People must prove that:

1.      The defendant took at least one direct but ineffective step toward killing (another person/ [or] a fetus);

AND

2.      The defendant intended to kill that (person/ [or] fetus).

A direct step requires more than merely planning or preparing to commit murder or obtaining or arranging for something needed to commit murder. A direct step is one that goes beyond planning or preparation and shows that a person is putting his or her plan into action. A direct step indicates a definite and unambiguous intent to kill. It is a direct movement toward the commission of the crime after preparations are made. It is an immediate step that puts the plan in motion so that the plan would have been completed if some circumstance outside the plan had not interrupted the attempt.

[A person who attempts to commit murder is guilty of attempted murder even if, after taking a direct step toward killing, he or she abandons further efforts to complete the crime, or his or her attempt fails or is interrupted by someone or something beyond his or her control. On the other hand, if a person freely and voluntarily abandons his or her plans before taking a direct step toward committing the murder, then that person is not guilty of attempted murder.]

[A person may intend to kill a specific victim or victims and at the same time intend to kill anyone in a particular zone of harm or “kill zone.” In order to convict the defendant of the attempted murder of    <insert name of victim charged in attempted
murder count[s] on concurrent-intent theory>, the People must prove

that the defendant not only intended to kill_______________ <insert
name of primary target alleged> but also either intended to kill <insert name of victim charged in attempted murder