N.J.S.A. 2C:17-1dmodel jury charge(first degree)
Count __ of the indictment charges the defendant with arson in violation of a statute which reads as follows: Any person who, directly or indirectly, pays or accepts or offers to pay or accept any form of consideration including, but not limited to, money or any other pecuniary benefit, regardless of whether any consideration is actually exchanged for the purpose of starting a fire or causing an explosion in violation of this section commits a crime. . .
In order to find the defendant guilty of arson, the State must prove each of the following elements beyond a reasonable doubt:
(1) that the defendant, directly or indirectly, paid, accepted or offered to pay or accept any form of consideration, regardless of whether any consideration is actually exchanged; and
(2) that the defendant paid, accepted or offered to pay or accept this consideration for the purpose of [starting a fire] [causing an explosion].
Consideration is something of value. In this case, the State alleges that the consideration was [describe the alleged consideration].
The first element that the State must prove beyond reasonable doubt is that the defendant, either directly or indirectly, [paid] [accepted][offered to pay or accept] any form of consideration1or inducement, including, but not limited to, money or any other pecuniary benefit.
The second element the State must prove beyond a reasonable doubt is that when the defendant [paid] [accepted][offered to pay or accept] this money (or any other pecuniary or non- pecuniary benefit) it was for the purpose of [starting a fire] [causing an explosion] in violation of the arson statute.
[CHARGE THIS SENTENCE IF APPLICABLE]
(The [fire need not have been started] [explosion need not have been caused], as the law