Proposed Mississippi Plain Language Model Jury Instructions - Criminal 2904

[Name of defendant] is charged in count ___ with agreeing to defraud the State of

Mississippi by interfering with or stopping payment of a State of Mississippi claim or preventing

a suit to enforce a State of Mississippi claim.

If you find beyond a reasonable doubt from the evidence in this case that:

1. On or about [date of alleged crime], in __________ County;

2. Intending to defraud the State of Mississippi, a department, or a political subdivision, [name of

defendant] and [name of co-defendant] unlawfully agreed:

A. To interfere with or stop a payment for a legal claim due to the State of Mississippi,

a department, or a political subdivision; or

B. To prevent a suit to enforce a legal claim by the State of Mississippi, a department,

or a political subdivision; or

C. To defraud the State of Mississippi, a department, or a political subdivision by

___________________ [describe defendant's alleged actions]; and

3. [Name of defendant] [and/or] [name of co-defendant] acted in a way to carry out their

agreement by ________________________________ [describe defendant's or co-defendant's

alleged actions],

then you shall find [name of defendant] guilty as charged.

If the State did not prove any one of the above listed elements beyond a reasonable doubt,

then you shall find [name of defendant] not guilty in count ___.