We have a case in which the defendant is charged with Theft $20,000-100,000. On the indictment, there are twelve separate paragraphs alleging the various thefts, and, at the end, there is the aggregation paragraph which alleges that everything was committing during a continuing course of conduct, etc.

Does anyone have a jury charge which would address this issue? I have looked through McClung's and the jury charge pool on the TDCAA site, but none of them have a charge for multiple paragraphs and aggregated thefts. If anyone has one, I would really appreciate your help. Thanks!

I don't have multiple paragraphs, but I'll email you an agg theft charge I have.

I'm glad someone responded saying they don't have the multiple paragraphs. I have a trial comeing up in 10 days and I have each theft alleged in the first paragraph and another paragraph alleging that it was all in the course of a scheme or continuing course of conduct. Is this really okay or do I need all those paragraphs? Thanks!


Steve Lilley