Ill. Pattern Jury Instr. (Criminal) 22.10X

To sustain the charge of communicating with a witness, the State must prove the

following propositions:

[1] First Proposition: That the defendant forcibly detained ____; and

Second Proposition: That when the defendant did so, ____ was a party or witness in a

matter pending [(in) (before )] [(a court) (a Grand Jury) (an administrative agency) (any State or

local governmental unit)]; and

Third Proposition: That when the defendant did so, he intended to deter ____ from

testifying freely, fully, and truthfully in the matter pending [(in) (before )] [(a court) (a Grand

Jury) (an administrative agency) (any State or local governmental unit)].

[or]

[2] First Proposition: That the defendant communicated directly or indirectly with ____;

and

Second Proposition: That when the defendant did so, ____ was a party or witness in a

matter pending [(in) (before )] [(a court) (a Grand Jury) (an administrative agency) (any State or

local governmental unit)]; and

Third Proposition: That the defendant communicated [( knowingly false information to

____) (a threat of injury or damage to the person or property of any individual)]; and

Fourth Proposition: That when the defendant did so, he intended to deter ____ from

testifying freely, fully, and truthfully to the matter pending [(in) (before )] [(a court) (a Grand

Jury) (an administrative agency) (any State or local governmental unit)].

[or]

[3] First Proposition: That the defendant [(offered) (delivered) (threatened to withhold)]

money [or other thing of value] [(to) (from)] any individual; and

Second Proposition: That when he did so, ____ was a party or witness in a matter

pending [(in) (before)] [(a court) (a Grand Jury) (an administrative agency) (any State or local

governmental unit)]; and

Third Proposition: That when he did so, the defendant intended to deter ____ from

testifying freely, fully, and truthfully in a matter pending [(in) (before )] [(a court) (a Grand Jury)

(an administrative agency) (any State or local governmental unit)].

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 of the evidence that any one of these

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

guilty.