Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3502

[Name of defendant] is charged in count ___ with using a credit card with the intent to

defraud.

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. [Name of defendant] unlawfully [received/obtained/got] __________ [specify money, goods,

property, services, or something of value], which [was/were] valued at less than $100.00, by:

A. Representing that [name of defendant] was the credit card owner without the credit

card owner's consent; or

B. Representing that [name of defendant] was the credit card owner knowing that no

credit card had been issued; or

C. Representing that [name of defendant] was authorized to use the credit card or the

credit card number,

intending to defraud the ____________ [specify credit card owner; credit card issuer; person who

provided the money, goods, property, services, or something of value; or organization which

provided the money, goods, property, services, something of value]; and

3. [Name of defendant] was previously convicted of ____________ [specify violation of §

97-19-21] in ___________ [list court and details of previous conviction] on __________ [list

date of previous conviction] [and of _______________ [specify violation of § 97-19-21] in

___________ [list court and details of previous conviction] on __________ [list date of previous

conviction]],

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 of count ___.