MS · jury_instructions
Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3737
Residential Mortgage Fraud
[Name of defendant] is charged in count ___ with residential mortgage fraud.
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. Intending to defraud [name of person], [name of defendant] [intentionally/knowingly] and
unlawfully made [a/an] [deliberate/intentional] [misstatement/misrepresentation/omission]
during the mortgage lending process, intending that it be relied on by [name of licensed mortgage
broker, mortgage lender, borrower, or other person in the mortgage lending process];
OR
2B. Intending to defraud [name of person], [name of defendant] [intentionally/knowingly] and
unlawfully [used/facilitated the use of] [a/an] [deliberate/intentional]
[misstatement/misrepresentation/omission], knowing that the
[misstatement/misrepresentation/omission] contained a
[misstatement/misrepresentation/omission] during the mortgage lending process and intending
that it be relied on by [name of company, borrower, or other person in the mortgage lending
process];
OR
2C. Intending to defraud [name of person], [name of defendant] [intentionally/knowingly] and
unlawfully received [proceeds/money/funds] in connection with a residential mortgage closing,
knowing that the [proceeds/money/funds] [resulted/came] from [a/an] [deliberate/intentional]
[misstatement/misrepresentation/omission] during the mortgage lending process;
OR
2D. Intending to defraud [name of person], [name of defendant] [intentionally/knowingly] and
unlawfully [conspired/agreed] __________________________ [specify (1) to make [a/an]
[deliberate/intentional] [misstatement/misrepresentation/omission] during the mortgage lending
process; (2) to [use/facilitate the use of] [a/an] [deliberate/intentional]
[misstatement/misrepresentation/omission] during the mortgage lending process; or (3) to receive
[proceeds/money/funds] which [resulted/came] from [a/an] [deliberate/intentional]
[misstatement/misrepresentation/omission] during the mortgage lending process];
OR
2E. Intending to defraud [name of person], [name of defendant] [intentionally/knowingly] and
unlawfully [filed/caused to be filed] with the chancery clerk of __________ County a deed of
trust, knowing that it contained [a/an] [deliberate/intentional]
[misstatement/misrepresentation/omission],
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 in count ___.
History
Proposed Mississippi Plain Language Model Jury Instructions - Criminal 3737 (current as of June 30, 2012). Submitted in 2012 by the Mississippi Model Jury Instructions Commission (created by the Supreme Court of Mississippi by order of December 30, 2008) and published by the Court on courts.ms.gov. The Court states that these model jury instructions have not been adopted or approved by the Supreme Court of Mississippi.
Provenance
- Source
- courts.ms.gov
- Retrieved
- 2026-09-25
- Edition
- 2026-09-25
- Content hash
786ed89bb97b40b7bdeb4505b7e2babef55f0e2f2fbe67b09f704166cfe42796
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