In Count _______ of the indictment, the defendant(s) is (are) charged with the crime of aggravated assault in that (he/she/they) allegedly on (Date) in the (Municipality)
(READ PERTINENT LANGUAGE OF INDICTMENT)
The defendant(s) is (are) accused of violating a section of our State statutes that reads as follows:
A person is guilty of aggravated assault if he … (a)ttempts to cause serious bodily injury to another, or causes such injury purposely or knowingly or under circumstances manifesting extreme indifference to the value of human life recklessly causes such injury.
Under this statute, the defendant(s) can be found guilty if (he/she/they) EITHER caused serious bodily injury to another OR attempted to cause serious bodily injury to another.
To find the defendant(s) guilty of aggravated assault for causing serious bodily injury to another, the State must prove beyond a reasonable doubt each of the following elements:
1. That the defendant(s) caused serious bodily injury to another; and
2. That the defendant(s) acted purposely or knowingly or acted recklessly under circumstances manifesting extreme indifference to the value of human life.
