3d Cir. Model Jury Instr. (Criminal) 4.29

You have heard testimony that the defendant (summarize the

other act evidence).

This evidence of other act(s) was admitted only for (a)

limited purpose(s). You may consider this evidence only for the

purpose of deciding whether the defendant (describe the precise purpose

or purposes for which the other act evidence was admitted: for example

(Pick those of the following, or other reasons, that apply)),

had the state of mind, knowledge, or intent necessary to commit the

crime charged in the indictment;

or

had a motive or the opportunity to commit the acts charged in the

indictment;

or

was preparing or planning to commit the acts charged in the

indictment;

or

acted with a method of operation as evidenced by a unique pattern

(describe);

or

did not commit the acts for which the defendant is on trial by

accident or mistake.;

or

is the person who committed the crime charged in the indictment.

You may consider this evidence to help you decide (describe how the

evidence will be used to prove identity B e.g., whether the evidence that the

defendant committed the burglary in which the gun that is the subject of

this trial was stolen makes it more likely that the defendant was the person

who placed the gun in the trunk of the car).

Do not consider this evidence for any other purpose.

Of course, it is for you to determine whether you believe this

evidence and, if you do believe it, whether you accept it for the purpose

offered. You may give it such weight as you feel it deserves, but only

for the limited purpose that I described to you.

The defendant is not on trial for committing these other acts.

You may not consider the evidence of these other acts as a substitute

for proof that the defendant committed the crime(s) charged. You may

not consider this evidence as proof that the defendant has a bad

character or any propensity to commit crimes. Specifically, you may

not use this evidence to conclude that because the defendant may have

committed the other act(s), (he)(she) must also have committed the

act(s) charged in the indictment.

Remember that the defendant is on trial here only for (state the

charges briefly), not for these other acts. Do not return a guilty verdict

unless the government proves the crime(s) charged in the indictment

beyond a reasonable doubt.