Conn. Crim. Jury Instr. 10.1-4

The defendant is charged [in count__] with criminal simulation. The statute defining this offense

reads in pertinent part as follows:

a person is guilty of criminal simulation when with intent to defraud, (he/she) makes

or alters any object in such manner that it appears to have an antiquity, rarity, source

or authorship which it does not in fact possess.

For you to find the defendant guilty of this charge, the state must prove the following elements

beyond a reasonable doubt:

Element 1 - Made or altered an object to falsify it

The first element is that the defendant made or altered an object in such manner that it appeared

to have an antiquity, rarity, source or authorship that it did not in fact possess. Simulation is the

assumption of a false appearance. Criminal simulation is a feigned or fictitious transaction to

effect a fraud.

Element 2 - Intent to defraud

The second element is that the defendant specifically intended to defraud another person. <See

Intent to Defraud, Instruction 2.3-6.>

Conclusion

In summary, the state must prove beyond a reasonable doubt that 1) the defendant made or

altered <insert type of object and describe how it had been falsified>, and 2) (he/she) intended to

defraud another person.

If you unanimously find that the state has proved beyond a reasonable doubt each of the elements

of the crime of criminal simulation, then you shall find the defendant guilty. On the other hand,

if you unanimously find that the state has failed to prove beyond a reasonable doubt any of the

elements, you shall then find the defendant not guilty.