AGGRAVATED ASSAULT - UNLAWFUL TAKING
OF A MOTOR VEHICLE
The defendant (Name) is charged in count with the crime of aggravated assault. The indictment alleges:
(READ APPROPRIATE COUNT OF INDICTMENT)
The statute upon which this charge is based provides:
A person is guilty of aggravated assault if he/she causes bodily injury to another person while operating a motor vehicle in violation of [another statute defining the offense of unlawful taking of a motor vehicle]...
In order for you to find the defendant guilty of this crime the State must prove the following elements beyond a reasonable doubt:
1. That defendant caused bodily injury to another person;
2. That defendant did so while operating a motor vehicle in violation of the statute defining the unlawful taking of a motor vehicle.
Bodily injury is defined as physical pain, illness or any impairment of physical condition. In order to find that the defendant caused bodily injury to (victim), you must find beyond a reasonable doubt, first, that (victim) would not have been injured but for defendant's conduct, and, second, that the bodily injury was a probable consequence of the defendant's conduct. A probable consequence is one which is not too remote, accidental in its occurrence or too dependent on the conduct of another to have a just bearing on defendant's liability or the gravity of his offense.
 N.J.S.A. 2C:11-1a.
 N.J.S.A. 2C:2-3e.
 State v. Martin, 119 N.J. 2 (1990).