A member of a conspiracy is criminally responsible for the crimes that he or she conspires to commit, no matter which member of the conspiracy commits the crime.

A member of a conspiracy is also criminally responsible for any act of any member of the conspiracy if that act is done to further the conspiracy and that act is a natural and probable consequence of the common plan or design of the conspiracy. This rule applies even if the act was not intended as part of the original plan. [Under this rule, a defendant who is a member of the conspiracy does not need to be present at the time of the act.]

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.

A member of a conspiracy is not criminally responsible for the act of another member if that act does not further the common plan or is not a natural and probable consequence of the common plan.

To prove that the defendant is guilty of the crime[s] charged in Count[s]            , the People must prove that:

1.              The defendant conspired to commit one of the following crimes: <insert target crime[s]>;

2.              A member of the conspiracy committed_____________
<insert nontarget offense[s]> to further the conspiracy;

AND

3.                                    <insert nontarget offense[s]> (was/were) [a]
natural and probable consequence[s] of the common plan or design of the crime that the defendant conspired to commit.

[The defendant is not responsible for the acts of another person who was not a member of the conspiracy even if the acts of the other person helped accomplish the goal of the conspiracy.]

[A conspiracy member is not responsible for the acts of other