SEQ CHAPTER \h \r 1CR05-511 07/29/05

PRIOR BAD ACTS

During the trial you may have heard testimony that (Def)_______________ may have ___________________________________________ at some time before the date of the alleged offense.  The law is strict about how you may use this evidence.  You may consider it as relevant to the issue of (use permitted under V.R.E. 404(b))_______________________________.  However, you may not consider this evidence as tending to prove that (Def)_______________ was acting in the same way or doing the same thing that [he] [she] did previously.  In other words, you may not consider evidence of (Def)_______________’s prior conduct as evidence that [he] [she] committed the alleged conduct for which [he] [she] is now on trial.