The People have presented evidence of a conspiracy. A member of a conspiracy is criminally responsible for the acts or statements of any other member of the conspiracy done to help accomplish the goal of the conspiracy.

To prove that (the/a) defendant was a member of a conspiracy in this case, 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 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.

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
instructions that I (will give/have given) you on (that/those) crime[s].

The People must prove that the members of the alleged conspiracy had an agreement and intent to commit_______________________________________________ <insert
alleged crime[s]>. The People do not have to prove that any of the members of the alleged conspiracy actually met or came to a detailed or formal agreement to commit (that/one or more of