Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3624

[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. [Name of defendant] [intentionally/knowingly/willfully] and unlawfully

[forged/counterfeited/caused to be forged/caused to be counterfeited/procured to be

forged/procured to be counterfeited] [a/an] __________ [specify the representation, likeness,

copy, imitation, or similitude of stamps, wrappers, or labels] usually [affixed/attached/used] by a

[manufacturer/mechanic] to and used by a [manufacturer/mechanic] [on/in/about] the sale of

goods, wares, or merchandise; and

3. The __________ [specify the goods or services] to which the [forged/counterfeit] __________

[specify the representation, likeness, copy, imitation, or similitude of stamps, wrappers, or labels]

[was/were] [affixed/attached/used], [was/were] valued at $1,000.00 or more,

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 ___.