CALCRIM No. 2315

11382)

The defendant is charged [in Count] with (selling/transporting/

administering/giving/furnishing/delivering) a substance in lieu of

<insert name of controlled substance> [in violation of

<insert appropriate code section[s]>].

To prove that the defendant is guilty of this crime, the People must

prove that:

1. The defendant (agreed/consented/offered/arranged/negotiated) to

(sell/transport/administer/give/furnish/deliver)

<insert name of controlled substance>, a controlled substance;

AND

2. After doing so, the defendant (sold/transported/administered/gave/

furnished/delivered) a substance in lieu of <insert

name of controlled substance>.

[Selling for the purpose of this instruction means exchanging the

substance for money, services, or anything of value.]

[A person transports something if he or she carries or moves it from one

location to another, even if the distance is short.]

[A person administers a substance if he or she applies it directly to the

body of another person by injection, or by any other means, or causes

the other person to inhale, ingest, or otherwise consume the substance.]

New January 2006