Va. Model Jury Instr. Crim. No. 24.500

The defendant is charged with the crime of threatening another person with [death; bodily

injury]. The Commonwealth must prove beyond a reasonable doubt each of the following elements

of that crime:

(1) That the defendant knowingly communicated [in writing; by an electronically transmitted

communication producing a visual or electronic message]; and

(2) That the [written communication; electronically transmitted communication producing a visual or

electronic message] contained a threat to [kill; do bodily injury to] (name of person who is the object

of the threat) regardless of whether (name of person who is the object of the threat) actually received

the threat; and

(3) That the threat to [kill; do bodily injury] placed [name of person who is the object of the threat;

any member of (name of threatened person)’s family] in reasonable fear of death or bodily injury to

[himself; his family member].

If you find that the Commonwealth has proved beyond a reasonable doubt each of the above

elements of the crime as charged, then you shall find the defendant guilty [but you shall not fix the

punishment until your verdict has been returned and further evidence has been heard by you].

If you find that the Commonwealth has failed to prove beyond a reasonable doubt any one or

more of the elements of the crime, then you shall find the defendant not guilty.