CALCRIM No. 1931

Code, § 475(b))

The defendant is charged [in Count] with possessing a (blank/

[or] unfinished) (check[,]/ [or] note[,]/ [or] money order[,]/ [or] traveler’s

check[,]/ [or] bank bill) with intent to defraud [in violation of Penal

Code section 475(b)].

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

prove that:

1. The defendant possessed a (blank/ [or] unfinished) (check[,]/ [or]

note[,]/ [or] money order[,]/ [or] traveler’s check[,]/ [or] bank

bill);

AND

2. When the defendant possessed the document, (he/she) intended to

complete [or aid the completion of] the document in order to

defraud.

Someone intends to defraud if he or she intends to deceive another

person either to cause a loss of (money[,]/ [or] goods[,]/ [or] services[,]/

[or] something [else] of value), or to cause 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).]

[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.]

[The (check[,]/ [or] note[,]/ [or] money order[,]/ [or] traveler’s check[,]/

[or] bank bill) may be real or fictitious.]

[The People allege that the defendant possessed the following documents:

<insert description of each document 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 at least one of these

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

New January 2006