Va. Model Jury Instr. Crim. No. 4.200

The defendant is charged with the crime of abduction. The Commonwealth must prove beyond

a reasonable doubt each of the following elements of that crime:

(1) That the defendant by [force; intimidation; deception] did [seize; take; transport; detain; hide]

(name of person); and

(2) That the defendant did so with the intent [to deprive (name of person) of his personal liberty; to

withhold or conceal (name of person) from (name of person or authority legally entitled to his charge)];

and

(3) That [the defendant did so with the intent to obtain money or other benefit of value; the defendant

did so with the intent to sexually molest (name of person); (name of person) was under the age of sixteen

(16) years and the abduction was for the purpose of prostitution or living together without being

married; that the abduction was for the purpose of prostitution; that the abduction was of a minor for the

purpose of manufacturing child pornography]; and

(4) That the defendant acted without legal justification or excuse.

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.