Ill. Pattern Jury Instr. (Criminal) 13.59

To sustain the charge of aggravated insurance fraud, the State must prove the following

propositions:

First Proposition: That the defendant knowingly made three or more claims to [(an

insurance company) (insurance companies)] under any insurance [(policy) (policies)] issued by

any insurance [(company) (companies)]; and

Second Proposition: That the defendant knew that all these claims were false; and

Third Proposition: That each claim allegedly arose out of a separate [(incident)

(transaction)]; and

Fourth Proposition: That the defendant knowingly and by deception [(obtained control)

(attempted to obtain control) (caused control to be obtained)] over the property of any insurance

[(company) (companies)] three times or more by making these false claims; and

Fifth Proposition: That the defendant did so within a period of 18 months; and

Sixth Proposition: That the defendant at all three or more times intended to permanently

deprive the insurance company of the use and benefit of the property.

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.