Does anyone have a sample indictment they can send me for continuous sexual abuse? I'm having trouble drafting the language, and I'm not sure if I need to list all offenses in one count, or several counts. Thanks!

[Defendant's name], hereinafter known as Defendant,

on or about [allege period of time with start and finish date] and

during a period that was 30 days or more in duration, committed two or more acts of sexual abuse against [allege name or names of victim(s)], said acts of sexual abuse having been violations of one or more of the following penal laws, including [identify each variation of the penal law that was violated]:

aggravated kidnapping of victim with the intent to violate or abuse victim sexually;

indecency with a child, by

- touching of the anus of victim;
- touching of any part of the genitals of victim;
- touching of any part of the body of victim with the anus of Defendant;
- touching of any part of the body of victim with any part of the genitals of Defendant;

aggravated sexual assault, namely,

- caused the penetration of the anus of victim, by [identify object];

- caused the penetration of the sexual organ of victim, by [identify object];

- caused the penetration of the mouth of victim by the sexual organ of Defendant;

- caused the sexual organ of victim to contact or penetrate the mouth of Defendant;

- caused the sexual organ of victim to contact or penetrate the anus of Defendant;

- caused the sexual organ of victim to contact or penetrate the sexual organ of Defendant;

- caused the anus of victim to contact the mouth of Defendant;

- caused the anus of victim to contact the anus of Defendant;

- caused the anus of victim to contact the sexual organ of Defendant;

- caused the mouth of victim to contact the anus of Defendant;

- caused the mouth of victim to contact the sexual organ of Defendant;


burglary of a habitation within intent to commit a felony, namely, [aggravated kidnapping with intent to violate or abuse the victim sexually, indecency with a child, or aggravated sexual assault] against victim;

sexual performance by a child, namely:

- knowing the character and content thereof, employed, authorized, or induced victim to engage in sexual conduct or a sexual performance;

- knowing the character and content of the material, produced, directed or promoted a performance that included sexual conduct by victim,

and each of the aforementioned acts of sexual abuse were committed on more than one occasion [delete this allegation if each act of sexual abuse was only committed on one occasion; or allege the language only after the acts of sexual abuse that were repeated]

and, at the time of the commission of each of the acts of sexual abuse, the defendant was 17 years of age or older and victim(s) was a child younger than 14 years of age.

Thanks JB. Doing one of these indictments right now and I was looking for a sample.

Here is an appellate case with a sample indictment:

Details.