Approved 12/13/99
The defendant (Name) is charged in count with the crime of aggravated assault. The indictment alleges:
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;
and
2. That defendant did so while operating a motor vehicle in violation of the statute defining the unlawful taking of a motor vehicle.
[1] N.J.S.A. 2C:11-1a.
[2] N.J.S.A. 2C:2-3e.
[3] State v. Martin, 119 N.J. 2 (1990).