CALCRIM No. 2001

(8))

The defendant is charged [in Count] with submitting multiple

insurance claims with intent to defraud [in violation of Penal Code

section 550(a)].

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

prove that:

1. The defendant presented two or more claims for (the same (loss/

[or] injury)/payment of the same health-care benefit) to (the

same/ [or] more than one) insurer;

2. The defendant knew that (he/she) was submitting two or more

claims for the same ((loss/ [or] injury)/health-care benefit);

AND

3. When the defendant presented the claims, (he/she) intended 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.]

A person presents a claim for payment by demanding payment under a

contract of insurance for (a/an) ((loss/ [or] injury)/ health-care benefit).

[A claim for payment of a health-care benefit includes a claim submitted

by or on behalf of the provider of a workers’ compensation health

benefit defined in the Labor Code.]

New January 2006; Revised February 2012