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 fleeing or attempting to elude a law enforcement officer in violation of [another statute defining the offense of eluding]…
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 fleeing or attempting to elude a law enforcement officer in violation of the statute defining the eluding offense.
