Ill. Pattern Jury Instr. (Criminal) 13.20

Victim 60 Years Of Age Or Older

To sustain the charge of theft, the State must prove the following propositions:

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

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

the property in question; and

Third Proposition: That the defendant intended to deprive the owner thereof permanently

of the use or benefit of that property;

[or]

Third 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]

Third 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

Fourth Proposition: That the property in question had a value of $5,000 or more; and

Fifth Proposition: That ____ was 60 years of age or older.

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.