SEQ CHAPTER \h \r 1CR04-081 06/18/03

UNANIMOUS VERDICT

Your verdict must be unanimous.  In connection with the charge of ____________________,  there has been evidence of different and separate acts.  The State need not have proven each of these different and separate acts, but before you may find (Def)_______________ guilty of the crime charged, you must all agree about which acts, if any, prove the essential elements of the crime charged.  You may not find (Def)_______________ guilty of the crime charged unless you all agree that the State has proven, beyond a reasonable doubt, that (Def)_______________ committed particular acts which prove the essential elements of the charge.  However, if the State has proven particular acts that prove each of the essential elements beyond a reasonable doubt, then you must return a verdict of guilty.