Conn. Crim. Jury Instr. 10.2-5

The defendant is charged [in count__] with the illegal transfer of a payment card. The statute

defining this offense imposes punishment on

any person other than the issuer who sells a payment card or buys a payment card

from a person other than the issuer.

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

beyond a reasonable doubt:

Element 1 - Bought or sold a payment card

The first element is that the defendant (sold / bought) a payment card. “Payment card” means

either a credit card or a debit card. “Credit card” means any instrument or device, whether

known as a credit card, as a credit plate, or by any other name, issued with or without fee by an

issuer for the use of a cardholder in obtaining money, goods, services or anything else of value

on credit. “Debit card” means any card, code, device or other means of access, or any

combination thereof, that is issued or authorized for use to debit an asset account held directly or

indirectly by a financial institution and that may be used by the cardholder to obtain money,

goods, services or anything else of value.

Element 2 - Not an issuer

The second element is that (the defendant / the person from whom the card was bought) is not

the issuer of the payment card. “Issuer” means the person or entity issuing a payment card, or a

duly authorized agent.

Conclusion

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

a payment card, and 2) (the defendant / the person from whom the card was bought) is not the

issuer of the payment card.

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

of the crime of the illegal transfer of a payment card, 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.