Conn. Crim. Jury Instr. 10.1-5

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 knowledge of its true character

and with intent to defraud, (he/she) issues or possesses an object that has been made

or altered in such manner that it appears to have an antiquity, rarity, source or

authorship that 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 - Issued or possessed a falsified object

The first element is that the defendant issued or possessed an object that had been made or

altered 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. <Insert as appropriate:>

• “Issuing” means signing, endorsing, circulating, distributing, publishing or the like.

• “Possession” means either having the object on one’s person or otherwise having control

over the object, that is, knowing where it is and being able to access it. Possession also

requires that the defendant knew that (he/she) was in possession of the <insert type of

written instrument>. That is, that (he/she) was aware that (he/she) was in possession of it

and was aware of its nature. The state must prove beyond a reasonable doubt that the

defendant knew that the <insert type of written instrument> was forged. <See

Possession, Instruction 2.11-1.>

Element 2 - Knowledge

The second element is that the defendant knew the true character of the object. A person acts

“knowingly” with respect to conduct or circumstances when (he/she) is aware that (his/her)

conduct is of such nature or that such circumstances exist. <See Knowledge, Instruction 2.3-3.>

Element 3 - Intent to defraud

The third 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 (issued /

possessed) <insert type of object and describe how it had been falsified>, 2) (he/she) knew the

true character of the object, and 3) (he/she) intended to (deceive / defraud / injure) 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.