Del. P.J.I. Crim. No. 11.877

OFFERING A FALSE INSTRUMENT FOR FILING

In order to find Defendant guilty of Offering a False Instrument for Filing, you

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

doubt:

(1) Defendant offered a written instrument to a public servant with the

knowledge or belief the instrument would become a part of the public records;

(2) Defendant knew or believed the written instrument contained a false

statement;

(3) Defendant acted with the intent to defraud; 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 harm or injury to another.

“Knowingly” means Defendant was aware that the written instrument contained a

false statement and it would become part of a public record.

“Written instrument" means any document or article containing written or

printed matter, used for the purpose of conveying or recording information, or

constituting a symbol or evidence of value, right, privilege or identification.

“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.