UJI 14-1613 NMRA
UJI 14-1613. Organized retail crime; theft.
For you to find _____________ (name of defendant) guilty of organized retail crime
[as charged in Count ___________]1, the state must prove to your satisfaction beyond a
reasonable doubt each of the following elements of the crime:
1. _____________ (name of defendant) and another person or persons acted with
an organized plan to steal merchandise from [a retailer2]3[retailers];
2. The aggregated retail market value4 of the merchandise stolen was two thousand
five hundred dollars ($2,500) or more;
3. _____________ (name of defendant) intended to [sell]3 [exchange] [return] the
merchandise for value;
4. This happened in New Mexico [on or about the ______________ day of
___________________, ____________]3 [within the span of one year, between the
__________________ day of _____________, ____________, and the
_____________ day of ____________, ___________].