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]:

[while a public servant or an officer or an employee of a financial institution, and the offense was committed under color of office or was made possible by that office];

[and the forgery or counterfeit is of foreign money or other legal tender, or utters or possesses any forged or counterfeited obligation or security of the government or foreign money or legal tender];

[and the forgery or counterfeit is of a writing from plates, dies, molds, photographs, or other similar instruments designed for multiple reproduction]; [and the forgery or counterfeit is of a writing that purports to have been made by the government]; or

[pursuant to a scheme to defraud another or others of money or property of a value in excess of one hundred 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 a writing] [or] [knowingly uttered or possessed a forged or counterfeited writing]; and [

2) The Defendant was acting as a public servant or an officer or an employee of a financial institution, and the offense was committed under color of office or was made possible by that office _______________;] [or] [

2) The Defendant forged or counterfeited foreign money or other legal tender, or uttered or possessed a certain forged or counterfeited obligation or security of the government or foreign money or legal tender, namely,_______________;] [or] [

2) The Defendant forged or counterfeited a certain writing, namely, _______________, from plates, dies, molds, photographs or other similar instruments designed for multiple reproduction;] [or] [2) The Defendant forged or counterfeited a certain writing, namely, _______________, that purports to have been made by the government;] [or] [

2) The forgery or counterfeit was done pursuant to a scheme to defraud another of money or property of a value in excess of one hundred dollars;] and [3) The Defendant, _______________, [acted with intent to deceive or harm the government or another person] [or] [knowingly facilitated that deception or harm by another person].

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

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