Ill. Pattern Jury Instr. (Criminal) 13.40

Use For Cases Where The Offense Is Alleged To Have Occurred Before January 1, 2012

To sustain the charge of forgery, the State must prove the following propositions:

[1] First Proposition: That the defendant knowingly [(made) (altered)] a _________so

that it appeared to have been made [(by another) (at another time) (with different provisions) (by

authority of one who did not give such authority)]; and

[or]

[2] First Proposition: That the defendant knowingly [(issued) (delivered)] a

__________which he knew had been made or altered so that it appeared to have been made [(by

another) (at another time) (with different provisions) (by authority of one who did not give such

authority)]; and

[or]

[3] First Proposition: That the defendant knowingly possessed, with intent to issue or

deliver a ________________, which he knew had been made or altered so that it appeared to

have been made [(by another) (at another time) (with different provisions) (by authority of one

who did not give such authority)]; and

[or]

[4] First Proposition: That the defendant knowingly and unlawfully used the digital

signature of another; and

[or]

[5] First Proposition: That the defendant knowingly and unlawfully used the signature

device of another to create an electronic signature of that other person; and

Second Proposition: That the defendant did so with an intent to defraud; and

Third Proposition: That the ___________was apparently capable of defrauding another.

If you find from your consideration of all the evidence that each one of these propositions

has been proved beyond a reasonable doubt, you should find the defendant guilty.

If you find from your consideration of all the evidence that any one of these propositions

has not been proved beyond a reasonable doubt, you should find the defendant not guilty.