Introductory Comment

As noted in the Introduction, this Manual is not intended to supply a set of universally applicable pattern instructions or to provide authoritative statements of law. The model instructions in the following sections are intended principally to set forth the elements of the offense in plain language consistent with the applicable statute. It is expected that judges will modify these models to adapt them to the facts and circumstances of the case before them and to take into account what is and is not in issue in the case. It may also be appropriate to supplement these instructions with some additional explanatory instructions addressed to particular evidence or contentions in the case. The model instructions, besides supplying text and form for the basic instruction on the elements, should be helpful in drafting or modifying other needed instructions in plain language and in a form conducive to maximum comprehension.