MUJI 2d CR1612

(DEFENDANT'S NAME) is charged [in Count__] with committing Sexual Abuse of a Child [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, knowingly, or recklessly:

[touched the anus, buttocks, or genitals of (MINOR'S INITIALS), even if accomplished through clothing]; or

[touched (MINOR'S INITIALS)'s breast, even if accomplished through clothing]; or

[took indecent liberties with (MINOR'S INITIALS)]; or

[caused (MINOR'S INITIALS) to take indecent liberties with (DEFENDANT'S NAME) or another]; and

Did so with the intent to:

[cause substantial emotional or bodily pain to any person]; or

[arouse or gratify the sexual desire of any person]; and

(MINOR'S INITIALS) was under 14 years old at the time of the conduct.

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.