Conn. Crim. Jury Instr. 10.6-1

The defendant is charged [in count__] with filing a fraudulent insurance claim. The statute

defining this offense imposes punishment on any person who <insert as appropriate:>

• obtains or attempts to obtain, from any (life / accident) insurance company of this state,

any money on any policy of insurance issued by it, by (falsely / fraudulently)

representing the insured person as (dead / injured).

• fraudulently obtains or attempts to obtain any money from any (life / accident) insurance

company of this state upon a policy of insurance issued in the name of a fictitious person.

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

beyond a reasonable doubt:

Element 1 - Obtained money

The first element is that the defendant obtained or attempted to obtain from any (life / accident)

insurance company of this state, any money on any policy of insurance issued by it.

Element 2 - By fraud or fictitious name

The second element is that the money was obtained <insert as appropriate:>

• by (falsely / fraudulently) representing the insured person as (dead / injured).

• fraudulently upon a policy of insurance issued in the name of a fictitious person.

A “fraudulent representation” is a representation whose purpose is to deceive. It is knowingly

untrue or made without belief in its truth and for the purpose of inducing action on it.

Conclusion

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

attempted to obtain from any life or accident insurance company of this state, any money on any

policy of insurance issued by it, and 2) (he/she) <insert specific allegations as to fraudulent

conduct>.

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

of the crime of defrauding a life or accident insurance company, 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.