Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3517

[Name of defendant] is charged in count ___ with issuing a bad check.

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 and with fraudulent intent

[made/wrote/drew/issued/passed/uttered/delivered] a _________ [specify check, draft, or order]

for $100.00 or more drawn on a [real/fictitious] __________ [specify bank, corporation, firm, or

person] to [obtain/get] _________ [specify money, delivery of valuable property, services, use of

property, or credit at a gaming establishment], knowing that the person who [made/wrote/drew]

the _________ [specify check, draft, or order] did not have sufficient funds in or on deposit with

the __________ [specify bank, corporation, firm, or person] for payment of the _________

[specify check, draft, or order] and all the other outstanding _________ [specify checks, drafts,

or orders] [made/written/drawn] on the funds,

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 ___.