Ill. Pattern Jury Instr. (Criminal) 13.30

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

First Proposition: That the defendant [(rented or leased [(a motor vehicle) (a ____

exceeding $500 in value)]) (obtained a motor vehicle through a “driveaway” mode of

transportation)] under an agreement in writing which provided for the return of the [(vehicle)

(____)] to a particular place at a particular time; and

Second Proposition: That the defendant without good cause wilfully failed to return the [

(vehicle) (____)] to that place within the time specified; and

Third Proposition: That the defendant thereafter was served or sent a written demand

mailed to the last known address, made by certified mail return receipt requested, to return such [

(vehicle) (____)] within 3 days from the mailing of the written demand; and

Fourth Proposition: That the defendant without good cause wilfully failed to return the [

(vehicle) (____)] to any place of business of the lessor within such period.

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 proposi tions

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