Del. P.J.I. Crim. No. 11.871(3)

FALSIFYING BUSINESS RECORDS

In order to find Defendant guilty of Falsifying Business Records, you must find

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

(1) Defendant failed to make a true entry in an enterprise’s business records

in violation of a duty to do so;

(2) Defendant knew the duty was imposed by law or the Defendant’s position;

(3) Defendant meant to defraud the enterprise; 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 it was Defendant’s conscious objective or purpose to

cause monetary injury or loss to the enterprise by means of deceit.