A person who, [with intent to deceive or harm the government or another person] [or] with knowledge that [he][she] is facilitating that deception or harm by another person], [knowingly and falsely makes, completes, or alters any writing] [or] [knowingly utters or possesses a forged or counterfeited writing] and [what [he][she] forged or counterfeited was an obligation or other security of the government] [or] [the forgery or counterfeit was done pursuant to a scheme to defraud another or others of money or property of a value in excess of ten thousand dollars] is guilty of Forgery or Counterfeiting.

ESSENTIAL ELEMENTS OF OFFENSE

The State’s burden of proof is satisfied if the evidence shows, beyond a reasonable doubt, the following essential elements:

1) On or about [month] [day] [year], in [County], North Dakota, the Defendant, _______________, [knowingly and falsely made, completed, or altered in writing] [or] [knowingly uttered or possessed a forged or counterfeited writing]; and

2) [The Defendant knowingly forged or counterfeited an obligation or other security of the government] [or] [this was done pursuant to a scheme to defraud ___________ or others of money or property of a value in excess of ten thousand dollars]; and 2) The Defendant [acted with intent to deceive or harm the government or another person] [or] [knowingly facilitated the deception or harm by another person].

DEFINITIONS [Insert relevant definitions. NDCC 12.1-01-04, 12.1-02-02, 12.1-24-04]

*****