Ill. Pattern Jury Instr. (Criminal) 13.18A

Based Upon Posing As A Landlord Or Agent Or Employee Of The Landlord

To sustain the charge of theft [(exceeding $ 500) (exceeding $500 and not exceeding

$10,000) (exceeding $10,000) (exceeding $10,000 and not exceeding $100,000) (exceeding

$100,000)], the State must prove the following propositions:

First Proposition: That ____ was the owner of the property in question; and

Second Proposition: That the defendant knowingly obtained by deception control over

property in the form of a [(rent payment) (security deposit)]; and

Third Proposition: That in doing so the defendant falsely posed as a [(landlord) (agent of

the landlord) (employee of the landlord)]; and

Fourth Proposition: That the defendant intended to deprive the owner thereof

permanently of the use or benefit of that property;

[or]

Fourth Proposition: That the defendant knowingly [(used) (concealed) (abandoned)] the

property in question in such manner as to deprive the owner thereof permanently of the use or

benefit of that property;

[or]

Fourth Proposition: That the defendant [(used) (concealed) (abandoned)] the property in

question knowing that such [(use) (concealment) (abandonment)] probably will deprive the

owner thereof permanently of the use or benefit of that property;

and

Fifth Proposition: That the property in question [(exceeded $500) (exceeded $500 and

not $10,000) (exceeded $10,000) (exceeded $10,000 but not $100,000) (exceeded $100,000)] in

value.

If you find from your consideration of all the evidence that each one of these propositions

has been proved beyond a reasonable doubt, you should find the defendant guilty.

If you find from your consideration of all the evidence that any one of these propositions

has not been proved beyond a reasonable doubt, you should find the defendant not guilty.