10th Cir. Crim. Pattern Jury Instr. 2.25

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

of 18 U.S.C. section 495.

This law makes it a crime to forge a signature on any paper

[for the purpose of obtaining] [for the purpose of enabling another

person to obtain] money from the United States or any of its

officers or agents.

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 wrote the signature of [name payee] on a

[describe written instrument] without his permission; and

Second: the defendant [did so for the purpose of obtaining

money from the United States when he knew he had no right to

have it] [did so for the purpose of enabling another person to obtain

money from the United States when the defendant knew the other

person had no right to have it].

The “payee” of a check is the true owner or person to whom

the check is payable.

The evidence does not have to show that the defendant or

anyone else actually obtained any money.

PATTERN CRIMINAL JURY INSTRUCTIONS

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