Barbara Fuller GOVT346
THE PEOPLE OF THE STATE OF ILLINOIS,
v.
Jeffrey BING.
No. 00 CR- 01234567.
STATE OF ILLINOIS )
) SS.
COUNTY OF COOK )
Defendant’s Motion for Self-Defense Jury Instruction
Introduction
According to 720 ILCS 5/9-1(a)(2), The client, Mr. Jeffrey Bing, was charged with murder. Mr.
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Jeffrey Bing is seeking a non-guilty verdict based on Illinois statute 720 Ill. Comp. Stat. 5/7-1,
We will be arguing for a not guilty verdict based on self-defense. According to the applicable
statutes and jury instructions, we are requesting the jury be instructed on self-defense. The
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protection from a murder conviction provided by Act 720 ILCS 5/7-1 applies to Mr. Bing. Mr.
Bing was left with no choice but to defend himself once Mr. Geller made several threats to kill
and subsequently charged the client while holding a knife despite the many attempts from my
client to verbally diffuse the situation prior to firing the single fatal shot at Mr. Geller.
Statement of facts
1 INDICTMENT FOR FIRST DEGREE MURDER. People v. Bing, No. 00 CR-01234567
2 IL-IPICRIM 24-25.06, Ill. Pattern Jury Instr.-Criminal 24-25.06 Use Of Force In Defense Of A Person
Barbara Fuller GOVT346
On August 2, 20XX Jeffrey Bing was on a camping trip with Mr. Geller and Mr. Newton.
As the friends were completing a day-long hike, Mr. Bing stated that he wanted to take a rest
break, even though they were only about 5 minutes from the lodge where they were staying. As
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they sat down in a meadow, a third friend, Mr. Newton, began goading Mr. Bing about a
weekend Mr. Bing had recently spent in New York with Mr. Geller’s former girlfriend. Mr. Id.
Geller was not aware of the relationship between the client and Ms. Jacoby. In Mr. Newton’s
statement to the police, he stated that when Mr. Geller discovered that Mr. Bing was seeing his
former girlfriend and that he had lied to him, he “went berserk.” Mr. Geller pounded on Mr. Id.
