Del. P.J.I. Crim. No. 11.876

TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE

In order to find Defendant guilty of Tampering with Public Records in the First

Degree, you must find the State has proved the following four (4) elements beyond a

reasonable doubt:

(1) Defendant made a false entry in, or falsely altered, any public record;

(2) Defendant acted without authority;

(3) Defendant acted with the intent to defraud; and

(3) Defendant acted knowingly

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

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

truth.

“Knowingly” means Defendant was aware the conduct would alter the public

record and, at the time of the tampering, Defendant was aware the conduct was

unauthorized.

“Intentionally” means it was Defendant’s conscious objective or purpose to

cause monetary harm or injury to another.