That on or about in the county of (County), (date), the defendant, caused the (defendant’s name), death of (specify); That the defendant did so by recklessly engaging in conduct which created a grave risk of death to and (specify); That the defendant engaged in such conduct under circumstances evincing a depraved indifference to human life. If you find the People have proven beyond a reasonable doubt each of those elements, you must find the defendant guilty of this crime. If you find the People have not proven beyond a reasonable doubt any one or more of those elements, you must find the defendant not guilty of this crime. 6
That on or about (date), in the county of (County), the defendant, (defendant’s name), caused the death of (specify); That the defendant did so by recklessly engaging in conduct which created a grave risk of death to (specify); and That the defendant engaged in such conduct under circumstances evincing a depraved indifference to human life. If you find the People have proven beyond a reasonable doubt each of those elements, you must find the defendant guilty of this crime. If you find the People have not proven beyond a reasonable doubt any one or more of those elements, you must find the defendant not guilty of this crime. 6
125-25(2).docx