CALCRIM No. 1921

Driver’s License (Pen. Code, § 470b)

The defendant is charged [in Count] with (possessing[,]/ [or]

displaying[,]/ [or] causing [or permitting] to be displayed) (an/a)

(altered[,]/ [or] falsified[,]/ [or] forged[,]/ [or] duplicated[,]/ [or]

reproduced[,]/ [or] counterfeited) (driver’s license/ [or] government -

issued identification card) [in violation of Penal Code section 470b].

To prove that the defendant is guilty of this crime, the People must

prove that:

1. The defendant (possessed[,]/ [or] displayed[,]/ [or] caused [or

permitted] to be displayed) a (driver’s license/ [or] government -

issued identification card);

2. The (driver’s license/ [or] government-issued identification card)

was (altered[,]/ [or] falsified[,]/ [or] forged[,]/ [or] duplicated[,]/

[or] reproduced[,]/ [or] counterfeited);

3. The defendant knew that the (driver’s license/ [or] government -

issued identification card) had been (altered[,]/ [or] falsified[,]/

[or] forged[,]/ [or] duplicated[,]/ [or] reproduced[,]/ [or]

counterfeited);

AND

4. When the defendant (possessed[,]/ [or] displayed[,]/ [or] caused

[or permitted] to be displayed) the (driver’s license/ [or]

government-issued identification card), (he/she) intended that the

document be used to commit forgery.

Someone intends to commit forgery if he or she intends to use a forged,

counterfeit, altered, falsified, duplicated, or reproduced document to

deceive another person in order to cause a loss of, or damage to, a legal,

financial, or property right.

[For the purpose of this instruction, a person includes (a governmental

agency/a corporation/a business/an association/the body politic).]

[A person alters a document if he or she adds to, erases, or changes a

part of the document that affects a legal, financial, or property right.]

[It is not necessary that anyone actually be defrauded or actually suffer

a financial, legal, or property loss as a result of the defendant’s acts.]

[Two or more people may possess something at the same time.]

[A person does not have to actually hold or touch something to possess

it. It is enough if the person has (control over it/ [or] the right to control

it), either personally or through another person.]

[The People allege that the defendant (possessed[,]/ [or] displayed[,]/ [or]

caused [or permitted] to be displayed) the following documents:

<insert description of each documents when multiple items

alleged>. Y ou may not find the defendant guilty unless you all agree that

the People have proved that the defendant (possessed[,]/ [or] displayed[,]/

[or] caused [or permitted] to be displayed) at least one of these

documents and you all agree on which document (he/she) (possessed[,]/

[or] displayed[,]/ [or] caused [or permitted] to be displayed).]

New January 2006