reasonable doubt that deliberately closed eyes to what would (name) (his) (her) otherwise have been obvious to (him) (her). No one can avoid responsibility for a crime by deliberately ignoring what is obvious. Thus, you may find that knew (name) (state the fact or circumstance, based on evidence which knowledge of which is required for the offense charged) proves that: (1) subjectively believed that there (name) (himself) (herself) [actually,] was a high probability that this existed, and (2) (fact) (circumstance) (name) consciously took deliberate actions to avoid learning [used deliberate efforts to avoid about the existence of this knowing] (fact) (circumstance). You may not find that knew (name) (state the fact or circumstance, knowledge if you find that the defendant actually of which is required for the offense charged) believed that this did not exist. Also, you may not find that (fact) (circumstance) knew (name) (state the fact or circumstance, knowledge of which is required for the if you find only that consciously disregarded a risk that the offense charged) (name) existed, or that should have known that the (fact) (circumstance) (name) (fact) existed, or that a reasonable person would have known of a high (circumstance) probability that the existed. It is not enough that may (fact) (circumstance) (name) have been reckless or stupid or foolish, or may have acted out of inadvertence or accident. You must find that subjectively (name) (himself) (herself) [actually,] believed there was a high probability of the existence of (state the fact or consciously took circumstance, knowledge of which is required for the offense charged),
reasonable doubt that (name) deliberately closed (his) (her) eyes to what would otherwise have been obvious to (him) (her). No one can avoid responsibility for a crime by deliberately ignoring what is obvious. Thus, you may find that (name) knew (state the fact or circumstance, knowledge of which is required for the offense charged) based on evidence which proves that: (1) (name) (himself) (herself) [actually,] subjectively believed that there was a high probability that this (fact) (circumstance) existed, and (2) (name) consciously took deliberate actions to avoid learning [used deliberate efforts to avoid knowing] about the existence of this (fact) (circumstance). You may not find that (name) knew (state the fact or circumstance, knowledge of which is required for the offense charged) if you find that the defendant actually believed that this (fact) (circumstance) did not exist. Also, you may not find that (name) knew (state the fact or circumstance, knowledge of which is required for the offense charged) if you find only that (name) consciously disregarded a risk that the (fact) (circumstance) existed, or that (name) should have known that the (fact) (circumstance) existed, or that a reasonable person would have known of a high probability that the (fact) (circumstance) existed. It is not enough that (name) may have been reckless or stupid or foolish, or may have acted out of inadvertence or accident. You must find that (name) (himself) (herself) [actually,] subjectively believed there was a high probability of the existence of (state the fact or circumstance, knowledge of which is required for the offense charged), consciously took
Chapter%205%20Rev%20April%202015.docx