Del. P.J.I. Crim. No. 11.861(b)(2)b

FORGERY IN THE SECOND DEGREE

In order to find Defendant guilty of Forgery in the Second Degree, you must

find the State has proved the following four (4) elements beyond a reasonable doubt:

(1) Defendant meant to defraud, deceive, or injure another person;

(2) Defendant altered ,completed, executed, authenticated, issued or

transferred another person’s written instrument without that other person’s authority;

(3) The written instrument was, or purported to be, a public record, or an

instrument filed (or required to be filed) with a public office or public servant; and

(4) Defendant acted intentionally.

“Defraud” means to acquire a gain or advantage by fraud.

“Fraud” means an intentional perversion, misrepresentation or concealment of

truth.

“Intentionally” means Defendant consciously altered, completed, executed,

authenticated, issued or transferred another person’s written instrument without that

other person’s authority.

“Public servant” means any officer or employee of the State or any political

subdivision thereof, including legislators and judges, and any person participating as

juror, advisor or consultant in performing a governmental function. The term does

not include witnesses. This definition includes persons who are candidates for office

or who have been elected to office, but who have not yet assumed office.