[I have explained that (the/a) defendant may be guilty of a crime if (he/she) either commits the crime or aids and abets the crime. (He/She) may also be guilty if (he/she) is a member of a conspiracy.]
 

(The defendant[s]/Defendant[s] ____________  <insert name[s]>) (is/

are) charged [in Count _________ ] with conspiracy to commit

______________ <insert alleged crime[s]> [in violation of Penal Code
section 182].

To prove that (the/a) defendant is guilty of this crime, the People must prove that:

1.      The defendant intended to agree and did agree with [one or more of] (the other defendant[s]/ [or]      <insert
name[s] or description[s] of coparticipant[s]>) to commit
                      <insert alleged crime[s]>;

2.      At the time of the agreement, the defendant and [one or more of] the other alleged member[s] of the conspiracy intended that one or more of them would commit
                      <insert alleged crime[s]>;

3.      (The/One of the) defendant[s][,] [or __________  <insert
name[s] or description[s] of coparticipant[s]>][,] [or (both/ all) of them] committed [at least one of] the following alleged overt act[s] to accomplish_ <insert

alleged crime[s]>: _________________ <insert the alleged overt
acts>;

AND

4.      [At least one of these/This] overt act[s] was committed in California placeholder.

To decide whether (the/a) defendant committed (this/these) overt act[s], consider all of the evidence presented about the act[s].

To decide whether (the/a) defendant and [one or more of] the

other alleged member[s] of the conspiracy intended to commit
____________ <insert alleged crime[s]>, please refer to the separate