Wis JI-Criminal 116

The defendant is charged with three separate counts of (name of offense).

The first count of the information in this case charges that:

[READ THE CHARGE IN THE FIRST COUNT.]

The second count of the information in this case charges that:

[READ THE CHARGE IN THE SECOND COUNT.]

The third count of the information in this case charges that:

[READ THE CHARGE IN THE THIRD COUNT.]

CONTINUE WITH ADDITIONAL COUNTS AS NECESSARY

The defendant has entered a plea of not guilty to each of these charges which means the

State must prove every element of each offense charged beyond a reasonable doubt.

Statutory Definition of the Crime

(Name of offense), as defined in § of the Criminal Code of Wisconsin is

committed by one who (refer to the uniform instruction for the summary definition of the

offense).

State's Burden of Proof

Before you may find the defendant guilty of any count of, the State must prove

by evidence which satisfies you beyond a reasonable doubt that the following elements

were present with respect to that count.

Elements of the Crime That the State Must Prove

SET FORTH THE ELEMENTS AS PROVIDED IN THE UNIFORM

INSTRUCTIONS, INCLUDING DEFINITIONS. THE WORDING OF SOME

ELEMENTS MAY NEED TO BE CHANGED TO FIT THIS FORMAT. IF THE

INSTRUCTION CALLS FOR A NAME TO BE USED, IT WILL USUALLY BE

SUFFICIENT TO REFER TO "THE PERSON NAMED IN THAT COUNT." 1

1. As to each count, .

2. As to each count, .

3. As to each count, .

4. As to each count, .

CONTINUE WITH ADDITIONAL ELEMENTS OR COUNTS AS NECESSARY

Jury's Decision

THE COMMITTEE RECOMMENDS SEPARATE CLOSING PARAGRAPHS

FOR EACH COUNT 2

If you are satisfied beyond a reasonable doubt that all elements of (name of offense)

have been proved as to Count One, you should find the defendant guilty of (name of

offense) as charged in Count One.

If you are not so satisfied, you must find the defendant not guilty as to Count One.

If you are satisfied beyond a reasonable doubt that all elements of (name of offense)

have been proved as to Count Two, you should find the defendant guilty of (name of

offense) as charged in Count Two.

If you are not so satisfied, you must find the defendant not guilty as to Count Two.

If you are satisfied beyond a reasonable doubt that all elements of (name of offense)

have been proved as to Count Three, you should find the defendant guilty of (name of

offense) as charged in Count Three.

If you are not so satisfied, you must find the defendant not guilty as to Count Three.

CONTINUE WITH ADDITIONAL COUNTS AS NECESSARY