Va. Model Jury Instr. Crim. No. 9.150

The defendant is charged with the crime of issuing two or more bad [checks; drafts; orders for the

payment of money] within a period of ninety (90) days. The Commonwealth must prove beyond a

reasonable doubt each of the following elements of that crime:

(1) That the defendant [wrote; uttered; delivered] two or more [checks; drafts; orders for the payment

of money] on the same account of a [bank; banking institution; trust company; depository]; and

(2) That each [check; draft; order for the payment of money] was made payable to the same

[corporation; firm; person]; and

(3) That the defendant knew at each of the times he acted that there were not sufficient [funds in;

credit with] the [bank; banking institution; trust company; depository] on which the [check; draft; order

for the payment of money] was written to cover payment of the [check; draft; order for the payment of

money]; and

(4) That each time the defendant acted with intent to defraud; and

(5) That the [checks; drafts; orders for the payment of money] were issued within a period of ninety

(90) days; and

(6) That the [checks; drafts; orders for the payment of money] had an aggregate represented value of

$1,000 or more; and

(7) That each [check; draft; order for the payment of money] was in payment as a present

consideration.

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 from the evidence 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.