Va. Model Jury Instr. Crim. No. 24.700

The defendant is charged with the crime of threatening to [intimidate the population at large;

influence the conduct or activities of (name of government) through intimidation; compel the emergency

evacuation, or avoidance, of any place of assembly, any building or other structure, or any means of

mass transportation]. The Commonwealth must prove beyond a reasonable doubt each of the

following elements of that crime:

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

producing a visual or electronic message] to (name recipient); and

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

electronic message] contained a threat to kill or do serious bodily injury to another; and

(3) That the defendant made such threat with the intent to [intimidate a civilian population at large;

influence the conduct or activities of [the government of the United States; a state; a locality] through

intimidation; compel the emergency evacuation, or avoidance, of [any place of assembly; any building;

any structure; any means of mass transportation]]; and

(4) That the defendant was 18 years of age or older at the time he communicated the threat.

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.