[Insert instructions for underlying offense.]

If you all agree the state has proved, beyond a reasonable doubt, each of the [number] elements listed above, you must next consider whether the defendant is not guilty because of the defense of bona fide experimentation for scientific research.

Scientific Research Defense

It is a defense to cruelty to nonlivestock animals that, at the time of the conduct, the person was engaged in bona fide experimentation for scientific research.

Burden of Proof

The defendant is not required to prove that he was engaged in bona fide experimentation for scientific research. Rather, the state must prove, beyond a reasonable doubt, that the defendant was not engaged in bona fide experimentation for scientific research.

Application of Law to Facts

To decide the issue of scientific research, you must determine whether the state has proved, beyond a reasonable doubt, that the defendant was not engaged in bona fide experimentation for scientific research.

If you all agree that the state has failed to prove, beyond a reasonable doubt, that the defendant was not engaged in bona fide experimentation for scientific research, you must find the defendant “not guilty.”

If you all agree the state has proved, beyond a reasonable doubt, each of the elements of the offense of cruelty to nonlivestock animals, and you all agree the state has proved, beyond a reasonable doubt, that the defendant was not engaged in bona fide experimentation for scientific research, you must find the defendant “guilty.”

[Insert any other instructions raised by the evidence. Then continue with the verdict form found in CPJC 2.1, the general charge.]