Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3612

[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;

2. Intending to defraud, [name of defendant] unlawfully [altered/forged/counterfeited/falsely

made] [a/an] _____________ [specify instrument or writing], which:

A. Was, or [purported/claimed] to be, a process issued by ____________ [specify court,

magistrate, or officer]; or

B. Was, or [purported/claimed] to be, a pleading or proceeding filed or entered in a court;

or

C. Was, or [purported/claimed] to be, a certificate, order, or allowance by __________

[specify court, board, or officer]; or

D. Was, or [purported/claimed] to be, a license or authority authorized by statute; or

E. Was, or [purported/claimed] to be, an instrument or writing made by [name of person]

in which a [pecuniary/financial/monetary] [demand/obligation] was, or

[purported/claimed] to be, [created/increased/discharged/diminished/decreased/affected],

by which the [altering/forging/counterfeiting/falsely making]

[affected/bound/injured/damaged/harmed] [name of person]’s person or property,

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 ___.