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Under the Model Penal Code, for the defendant to be convicted of attempt requires that the defendant have performed a "substantial step in a course of conduct planned to culminate in [the defendant']s commission of the crime" [MPC 5.01(1)(c)].

Similarly, the only way to discern intent is from an objective manifestation of it, even if it is as to a completed crime--in which case its pretty cut and dry, because the manifestation of intent is the completed crime. For instance, if an individual were to enter a bank and pass a note to a teller ordering the teller to hand over cash--even if the individual never took the cash from the teller--this would be considered evidence of an intent to commit the robbery. Simply entering the bank and silently thinking about committing the robbery, but doing nothing, would be insufficient, because there is no objective manifestation of intent.

Distinguish intent from motive, and intentfrom attempt.

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Q: What constitutes prima facie evidence of an intent to steal?
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