Va. Model Jury Instr. Crim. No. 28.100

The defendant is charged with using a false statement to obtain property or credit. The

Commonwealth must prove beyond a reasonable doubt each of the following elements of the

crime:

(1) That the defendant knew that a false statement had been made in writing; and

(2) That the false statement concerned the financial condition or ability to pay of [the defendant;

any person for whom he was acting; any firm or corporation in which he was interested; any firm or

corporation for which he was acting]; and

(3) That the defendant, with the intent to defraud, procured, upon the faith of the false statement,

any [delivery; payment; loan; credit; extension; discount making; acceptance; sale; endorsement] for [his

own benefit; the benefit of any person for whom he was acting; any firm or corporation in which he was

interested; any firm or corporation for which he was acting]; and

(4) That the [value of the thing; the amount of the loan, credit or benefit] obtained was $1000 or more.

If you find that the Commonwealth has proved beyond a reasonable doubt each of the above

elements of the crime as charged, then you shall find the defendant guilty [but you shall not fix the

punishment until your verdict has been returned and further evidence has been heard by you].

If you find that the Commonwealth has failed to prove beyond a reasonable doubt any one or

more of the elements of the crime, then you shall find the defendant not guilty.