Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3613

[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 possessed a [forged/altered/counterfeit]

__________ [specify negotiable note, bill, draft, or other evidence of debt], issued, or

[purportedly/claiming] to be issued, by ___________ [specify corporation or company authorized

by the laws of the United States, Mississippi, or another state, government, or country], knowing

that the __________ [specify negotiable note, bill, draft, or other evidence of debt] was

[forged/altered/counterfeited] and intending ____________________ [specify (1) to [utter/pass]

the __________ [specify negotiable note, bill, draft, or other evidence of debt] or (2) to cause the

____________ [specify negotiable note, bill, draft, or other evidence of debt] to be

[uttered/passed]],

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 ___.