Del. P.J.I. Crim. No. 4.4

EVIDENCE OF OTHER ALLEGED CRIMES, WRONGS, OR ACTS

You [are about to hear/have heard] evidence of certain acts allegedly

committed by the defendant. These acts are other than the alleged wrongdoing for

which the defendant is now on trial.

You may not consider these other acts for the purpose of concluding that the

defendant has a certain character, or character trait, and was acting in conformity

with that character or character trait with respect to the crimes charged in this case.

You may not use the evidence of other acts to conclude that the defendant is a bad

person, or has a tendency to commit criminal acts, and is therefore probably guilty

of the charged crimes.

You may use evidence relating to other acts allegedly committed by the

defendant only to determine issues relevant to the charged crimes. In this case, the

State contends that the evidence of other acts relates to the defendant's [motive,

opportunity, intent, preparation, plan, knowledge, identity, absence of mistake or

accident, consciousness of guilt, proof of consent or lack of consent, presence or

absence of extreme emotional distress, presence or absence of certain psychiatric

or psychological conditions, mental state, etc.]. You may consider such evidence

or other acts for this purpose only.

As with any other evidence presented at trial, you, the jurors, are the sole

finders of fact. You must decide what, if any, weight the evidence should be

given.