5th Cir. Pattern Jury Instr. (Criminal) 2.20

18 U.S.C. § 472

Title 18, United States Code, Section 472, makes it a crime for anyone to possess [pass]

[utter] [publish] [sell] [attempt to pass] [attempt to utter] [attempt to publish] [attempt to sell]

counterfeit United States money with intent to defraud.

For you to find the defendant guilty of this crime, you must be convinced that the

government has proved each of the following beyond a reasonable doubt:

First: That the defendant possessed [passed] [uttered] [published] [sold] [attempted to pass]

[attempted to utter] [attempted to publish] [attempted to sell] counterfeit money;

Second: That the defendant knew at the time that the money was counterfeit; and

Third: That the defendant possessed [passed] [uttered] [published] [sold] [attempted to

pass] [attempted to utter] [attempted to publish] [attempted to sell] the counterfeit money with

intent to defraud, that is, intending to cheat someone by making that person think the money was

real.

However, the government does not need to prove that the defendant intended to cheat a

particular person, or that the United States or anyone else was in fact cheated, so long as the

government proves beyond a reasonable doubt that the accused acted with intent to cheat someone.