Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3609

[Name of defendant] is charged in count ___ with forgery.

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

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

2A. [Name of defendant] unlawfully [made/engraved/caused to be made/caused to be engraved]

a false plate in the form of _____________ [specify a promissory note, bill of exchange, draft,

check, certificate of deposit, or other evidence of debt] issued by [a/an] _____________ [specify

(1) incorporated bank in the State of Mississippi; (2) bank incorporated under the laws of the

United States, a state or territory; or (3) bank incorporated under the laws of a foreign country or

government], without the authority of the bank, intending to [use/have the plate used] to take an

impression to be [passed/sold/altered];

OR

2B. [Name of defendant] unlawfully possessed a plate, which had engraved [figures/words] and

could be used to falsely alter an evidence of debt issued by a ________________ [specify (1)

incorporated bank in the State of Mississippi; (2) bank incorporated under the laws of the United

States, a state or territory; or (3) bank incorporated under the laws of a foreign country or

government], intending to use the plate to falsely alter an evidence of debt;

OR

2C. [Name of defendant] unlawfully possessed an impression taken from a plate, without the

authority of ________________ [specify (1) incorporated bank in the State of Mississippi; (2)

bank incorporated under the laws of the United States, a state or territory; or (3) bank

incorporated under the laws of a foreign country or government], intending to have the

impression filled up and completed in order to be [passed/sold/uttered],

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 ___.