Va. Model Jury Instr. Crim. No. 29.320

The defendant is charged with the crime of taking indecent liberties with a child with whom he

maintained a custodial or supervisory relationship. The Commonwealth must prove beyond a

reasonable doubt each of the following elements of that crime:

(1) That the defendant, with lascivious intent, knowingly and intentionally [proposed that the child

feel or fondle the sexual or genital parts of the defendant; proposed that the defendant feel or handle the

sexual or genital parts of the child; proposed to the child the performance of an act of sexual intercourse,

anal intercourse, cunnilingus, fellatio, anilingus, or any act constituting an offense under Va. Code Ann.

§ 18.2-361; exposed [his; her] sexual or genital parts to the child; proposed to the child that the child

engage in [sexual intercourse; sodomy; fondling of sexual or genital parts with another person]; sexually

abused the child by (description of an act defined as sexual abuse in Va. Code § 18.2-67.10(6))]; and

(2) That the child was under the age of 18 at the time; and

(3) That the defendant was 18 or older at the time;

(4) That the defendant at the time maintained a custodial or supervisory relationship over (name of

child); and

(5) The defendant at the time was not married to (name of child).

If you find from the evidence 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.