The defendant is charged in Count[s] with ________________  <insert target offense> and in Counts[s] with __________________ <insert non-target offense>.

You must first decide whether the defendant is guilty of
_____________ <insert target offense>. If you find the defendant is
guilty of this crime, you must then decide whether (he/she) is

guilty of____________ <insert non-target offense>.

Under certain circumstances, a person who is guilty of one crime may also be guilty of other crimes that were committed at the same time.

To prove that the defendant is guilty of______________ <insert non-

target offense>, the People must prove that:

1.      The defendant is guilty of_____________ <insert target
offense>;

2.      During the commission of_____________ <insert target

offense> a coparticipant in that______________ <insert target

offense> committed the crime of______________ <insert non-

target offense>;

AND

3.      Under all of the circumstances, a reasonable person in the defendant’s position would have known that the

commission of_____________ <insert non-target offense> was

a natural and probable consequence of the commission of the      <insert target offense>.

A coparticipant in a crime is the perpetrator or anyone who aided and abetted the perpetrator. It does not include a victim or innocent bystander.

A natural and probable consequence is one that a reasonable person would know is likely to happen if nothing unusual intervenes. In deciding whether a consequence is natural and probable, consider all of the circumstances established by the evidence. If the          <insert non-target offense> was committed for a reason independent of the common plan to