CALCRIM No. 2020

Code, § 532a(1))

The defendant is charged [in Count] with (making/ [or] causing

to be made) a false written statement about (his/her/another person’s/a

corporation’s) (financial condition[,]/ [or] means[,]/ [or] ability to pay)

[in violation of Penal Code section 532a(1)].

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

prove that:

<Alternative 1A—statement made about defendant himself/herself>

[1. The defendant (made/ [or] caused to be made) a false written

statement about (his/her) (financial condition[,]/ [or] means[,]/ [or]

ability to pay);]

<Alternative 1B—statement made about someone else or a corporation>

[1. The defendant (made/ [or] caused to be made) a false written

statement about the (financial condition[,]/ [or] means[,]/ [or]

ability to pay) of (another person/a firm or corporation (in which

the defendant had an interest/ [or] for which the defendant was

acting));]

2. The defendant knew that the statement was false;

3. When the defendant (made the statement/ [or] caused the

statement to be made), (he/she) intended that the statement be

relied on;

AND

4. The defendant (made the statement/ [or] caused the statement to

be made) to obtain the (delivery of personal property[,]/ [or]

payment of cash[,]/ [or] making of a loan[,]/ [or] extension of

credit[,]/ [or] execution of a contract of guaranty or suretyship[,]/

[or] discount of an account receivable[,]/ [or] making, acceptance,

discount, sale, or endorsement of a bill of exchange or promissory

note) for ((his/her) benefit/the benefit of the (other person/

corporation)).

[A person may (make a false statement/ [or] cause a false statement to be

made) either directly or indirectly, or through his or her agent. An agent

is someone authorized by the defendant to act for (him/her) in dealings

with third parties.]

[The People allege that the defendant (made/ [or] caused to be made) the

following statements: <insert description of each statement

when multiple statements alleged>. Y ou may not find the defendant guilty

unless you all agree that the People have proved that the defendant

(made/ [or] caused to be made) at least one of these statements and that

the statement was false. Y ou must all agree on which false statement (he/

she) (made/ [or] caused to be made).]

New January 2006