MUJI 2d CR1303

(DEFENDANT'S NAME) is charged [in Count ____] with committing Assault Against a School Employee [on or about (DATE)]. You cannot convict [him] [her] of this offense unless, based on the evidence, you find beyond a reasonable doubt each of the following elements:

(DEFENDANT'S NAME);

[intentionally or knowingly attempted, with unlawful force or violence, to do bodily injury to (VICTIM'S NAME); or]

[intentionally, knowingly, or recklessly

[committed an act with unlawful force or violence that

caused bodily injury to (VICTIM'S NAME); or

created a substantial risk of bodily injury to (VICTIM'S NAME); or]

[threatened to commit any offense involving bodily injury, death, or substantial property damage, and acted with intent to place (VICTIM'S NAME) in fear of imminent serious bodily injury, substantial bodily injury, or death; or]

[made a threat, accompanied by a show of immediate force or violence, to do bodily injury to (VICTIM'S NAME);]]

(DEFENDANT'S NAME) had knowledge that (VICTIM'S NAME) was an employee or volunteer of a public or private school;

(VICTIM'S NAME) was acting within the scope of (his)(her) authority as an employee or volunteer of a public or private school; and

[The defense of _______________ does not apply.]

After you carefully consider all the evidence in this case, if you are convinced that each and every element has been proven beyond a reasonable doubt, then you must find the defendant GUILTY. On the other hand, if you are not convinced that each and every element has been proven beyond a reasonable doubt, then you must find the defendant NOT GUILTY.