†SEQ CHAPTER \h \r 1CR27-135 03/30/07




13 V.S.A. ß 2635(a)(5)


The State has charged (Def)_______________ with [inducing] [enticing] [procuring] [compelling] another person to live a life of prostitution, as follows:

[Read the charge.]

Every crime is made up of essential elements.† Before (Def)_______________ can be found guilty of the charge, the State must have proven each of the essential elements beyond a reasonable doubt.† In this case, the essential elements are that on the date and at the place alleged,

(1) (Def)_______________;

(2) [induced] [enticed] [procured] [compelled] (person)_______________ to live a life of prostitution, by (specific acts)____________________; and

(3) [he] [she] did so intentionally.

The first essential element is that (Def)_______________ is the person who committed the alleged acts.

The second essential element is that (Def)_______________ [induced] [enticed] [procured] [compelled] (person)_______________ to live a life of prostitution.

[To induce means to lead by persuasion or reasoning.]

[To entice a person means to tempt or lure that person to do something.]

[To procure means to get and make available for a particular purpose.]

[To compel means to threaten or to use force or pressure, so as to overcome the free will of the other person.]

The term prostitution means the offering or receiving of the body for sexual intercourse for hire.† The term sexual intercourse refers to the insertion of a manís erect penis into a womanís vagina.† The term for hire means that the sexual intercourse was exchanged for something of value.

To establish a life of prostitution, the State must have proven one or more instances of sexual intercourse for hire.† However, specific instances alone, if you find such instances, are not sufficient.† Rather, this element requires a showing that during the entire charged time period, (person)_______________ís way or manner of life was to engage in sexual intercourse for hire.† In determining whether or not (person)_______________ lived a life of prostitution, you should consider all of the facts and circumstances surrounding both (Def)_______________ and (person)_______________, along with their respective acts, conduct and statements.

The last essential element is that (Def)_______________ intentionally engaged in the conduct charged.† [He] [She] must have acted purposely, and not inadvertently, because of mistake, or by accident.† You may find that (Def)_______________ acted intentionally if it was [his] [her] conscious objective to cause (person)_______________ to live a life of prostitution.

A personís intent may be shown by the way in which the person expresses it to others, or by his or her conduct.† In determining (Def)_______________ís intent, you should consider all of the surrounding facts and circumstances established by the evidence.

Here the State alleges that (Def)_______________ intentionally [induced] [enticed] [procured] [compelled] (person)_______________ to live a life of prostitution, by (specific acts)_________________________.

All of the elements of the offense must have been present at the same time.† If the State has not proven each of the essential elements of the charge beyond a reasonable doubt, then you must find (Def)_______________ not guilty.† However, if the State has proven all of the essential elements beyond a reasonable doubt, you must return a verdict of guilty.