5th Cir. Pattern Jury Instr. (Criminal) 2.22A

SECURITY OF THE UNITED STATES

18 U.S.C. § 510(a)(1)

Title 18, United States Code, Section 510(a)(1), makes it a crime for anyone with intent to

defraud to falsely make or forge any endorsement or signature on a Treasury check, bond, or

security of 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 ____________________ ( describe conduct, e.g., forged the

signature of another on the Treasury check[s]);

Second: That the defendant did so with intent to defraud, that is, intending to cheat or

deceive someone.

The evidence does not have to show that anyone actually received anything of value as a

result of the forged signature; and

Third: That the face value of the check [aggregate face value of the checks if more than

one] was more than $1,000.

The “payee” of a check [bond] [security] is the person to whom the check [bond] [security]

is payable.

To “forge” means to write a payee’s endorsement or signature on a Treasury check [bond]

[security] without the payee’s permission or authority.