UJI 14-951 NMRA
UJI 14-951. Criminal sexual penetration in the second degree; threats of force or coercion; aided or abetted by another; essential elements.
For you to find the defendant guilty of criminal sexual penetration when aided or
abetted by another [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. The defendant2
[caused _______________ (name of victim) to engage in __________3;]
[OR]
[caused the insertion, to any extent, of a ___________________4 into the
_________________5 of __________________ (name of victim);]
2. The defendant
[used threats of physical force or physical violence against ___________________
(name of victim or other person);]2
[OR]
[threatened to __________________________6;]
3. __________________ (name of victim) believed the defendant would carry out
the threat;
4. The defendant acted with the help or encouragement of one or more persons;
[5. The defendant’s act was unlawful;]7
6. This happened in New Mexico on or about the ____ day of ______________,
_______.