Conn. Crim. Jury Instr. 10.1-6

The defendant is charged [in count__] with forgery of symbols. The statute defining this offense

reads in pertinent part as follows:

a person is guilty of forgery of symbols of value when, with intent to defraud, deceive

or injure another, (he/she) <insert as appropriate:>

• falsely (makes / completes / alters) a written instrument,

• (issues / possesses) any written instrument that (he/she) knows to be forged,

which is or purports to be, or which is calculated to become or represent if completed,

part of an issue of <insert as appropriate:>

• tokens.

• public transportation transfers.

• certificates.

• articles manufactured and designed for use as symbols of value usable in place of money

for the purchase of property or services.

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

beyond a reasonable doubt:

Element 1 - Made, falsified, issued or possessed a written instrument The first element is that

the defendant <insert as appropriate:>

• falsely (made / completed / altered) a written instrument.

• (issued / possessed) any written instrument that (he/she) knew to be forged.

A “written instrument” is any instrument or article containing written or printed matter or the

equivalent thereof, used for the purpose of reciting, embodying, conveying, or recording

information or constituting a symbol or evidence of value, right, privilege or identification,

which is capable of being used to the advantage or disadvantage of some person. A “forged

instrument” means a written instrument which has been falsely made, completed or altered.

For this offense, the written instrument must be part of an issue of <insert as appropriate:>

• tokens.

• public transportation transfers.

• certificates.

• articles manufactured and designed for use as symbols of value usable in place of money

for the purchase of property or services.

<Describe the written instrument at issue.>

[<If charged with falsely making, completing, or altering, insert appropriate definitions:>

• A written instrument may be complete or incomplete. A “complete written instrument” is

a written instrument that is fully drawn with respect to every essential feature thereof,

whereas an “incomplete written instrument” is one that contains some matter by way of

content or authentication but requires additional matter in order to render it a complete

written instrument.

• A person “falsely makes” a written instrument when

o (he/she) makes or draws a complete written instrument in its entirety, or an

incomplete written instrument, which purports to be an authentic creation of its

ostensible maker or drawer, but which is not such either because the ostensible maker

or drawer is fictitious or because, if real, (he/she) did not authorize the making or

drawing thereof.

o (he/she) signs (his/her) own name to a written instrument, thereby falsely and

fraudulently representing that (he/she) has authority to sign in such capacity.

• A person “falsely completes” a written instrument when

o (he/she), by adding, inserting or changing matter, transforms an incomplete written

instrument into a complete one, without the authority of anyone entitled to grant it, so

that such complete instrument appears or purports to be in all respects an authentic

creation of or fully authorized by its ostensible maker or drawer.

o (he/she) signs (his/her) own name to a written instrument, thereby falsely and

fraudulently representing that (he/she) has authority to sign in such capacity.

• A person “falsely alters” a written instrument when,

o (he/she), without the authority of any person entitled to grant it, changes a written

instrument, whether it be in complete or incomplete form, by means of erasure,

obliteration, deletion, insertion of new matter, transposition of matter, or in any other

manner, so that such instrument in its thus altered form appears or purports to be in

all respects an authentic creation of or fully authorized by its ostensible maker or

drawer.

o (he/she) signs (his/her) own name to a written instrument, thereby falsely and

fraudulently representing that (he/she) has authority to sign in such capacity.

The term “falsely” does not refer to the content or tone of the writing, or to the fact stated in the

writing, but implies that the paper is false, not genuine, fictitious, not a true writing, without

regard to the truth or falsehood of the statement it contains.]

[<If charged with issuing and/or possessing, insert appropriate definitions:>

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

state must prove that the defendant knew that the <insert type of written instrument> was

forged. 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.>]

• “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 - Intent

The second element is that the defendant had the specific intent to (deceive / defraud / injure)

another person. A person acts “intentionally” with respect to a result when (his/her) conscious

objective is to cause such result. <See Intent: Specific, Instruction 2.3-1.>

Conclusion

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

falsely completed / falsely altered / issued / possessed) a <insert type of written instrument>

[<insert only if the allegation is issuing or possessing> that (he/she) knew to have been forged],

and 2) (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 forgery of symbols, 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.