Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3625

[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] unlawfully possessed [a/an] ____________ [specify die, plate, engraving,

or printed label, stamp, or wrapper, or any representation, likeness, similitude, copy, or imitation

of the private stamp, wrapper, or label] usually [affixed/attached] by a [manufacturer/mechanic]

and used by the [manufacturer/mechanic] [on/in/about] the sale of goods, wares, or merchandise,

intending to [use/sell] the ____________ [specify die, plate, engraving, or printed label, stamp,

or wrapper, or any representation, likeness, similitude, copy, or imitation of the private stamp,

wrapper, or label] to [aid/assist/help] in the [selling/vending] of imitation goods, wares, or

merchandise or the [selling/vending] of goods, wares, or merchandise meant to resemble the

[manufacturer/mechanic]’s goods, wares, or merchandise,

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 ___.