5th Cir. Pattern Jury Instr. (Criminal) 2.21B

18 U.S.C. § 495 (SECOND PARAGRAPH)

Title 18, United States Code, Section 495, makes it a crime for anyone to utter or publish

as true any false, forged, altered, or counterfeited writing, with intent to defraud the United States.

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 _______________________ (e.g., cashed a forged United States

Treasury check ) and in doing so stated or implied, directly or indirectly, that the

_______________________ (e.g., check) was genuine;

Second: That the defendant knew at the time that ___________________ (e.g., the check)

was false [forged] [altered] [counterfeited]; and

Third: That the defendant _____________________ (e.g., cashed the forged United States

Treasury check) with intent to defraud, that is, intending to cheat the United States government.

The evidence does not have to show that anyone actually received any money as a result

of __________________ (e.g., the cashing of the forged United States Treasury check).