Ill. Pattern Jury Instr. (Criminal) 13.65

To sustain the charge of home repair fraud, the State must prove the following

propositions:

First Proposition: That the defendant knowingly entered into [(an agreement) (a

contract)] with a person for home repair; and

[1] Second Proposition: That the defendant knowingly misrepresented a material fact

relating to [(the terms of the [(agreement) (contract)]) (the preexisting or existing

condition of any portion of the property involved)] [(.) (; and)]

[or]

[2] Second Proposition: That the defendant knowingly [(created) (confirmed)] another's

impression which was false and which he did not believe to be true[(.) (; and)]

[or]

[3] Second Proposition: That the defendant knowingly promised performance which he

did not intend to perform or knew would not be performed[(.) (; and)]

[or]

[4] Second Proposition: That the defendant knowingly used or employed any [

(deception) (false pretense) (false promises)] in order to induce, encourage, or solicit

such person to enter into any [(agreement) (contract)] [(.) (; and)]

[Third Proposition: That the amount of the [(agreement[s] ) (contract[s] )] exceeded

$1,000[(.) (; and)]]

[Fourth Proposition: That the defendant entered into such [(agreement[s] ) (contract[s] )

] as part of or in furtherance of a common fraudulent scheme, design, or intention.]

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.