10th Cir. Crim. Pattern Jury Instr. 2.23

The defendant is charged in count ————— with a violation

of 18 U.S.C. section 471.

This law makes it a crime to, falsely make, forge, counterfeit,

or alter any obligation or other security of the United States with

intent to defraud.

[Name obligation or security] is an obligation or security of

the United States within the meaning of the law.

T o fi n d t h e d e f e n d a n t g u i l t y o f t h i s c r i m e y o u m u s t b e

convinced that the government has proved each of the following

beyond a reasonable doubt:

First: the defendant [falsely made] [forged] [counterfeited]

[altered] [name obligation or security]; and

Second: the defendant did so with intent to defraud.

[An item is “counterfeit” if it bears such a likeness to a genuine

item as is calculated to deceive an unsuspecting person of ordinary

observation and care.]

To act with “intent to defraud” means to act with intent to

cheat or deceive. It does not matter, however, whether anyone was

in fact cheated or deceived.