A person who, with intent to deceive or harm the government or another person [or facilitate that deception or harm by another person], [knowingly and falsely makes, completes, or alters any writing] [knowingly alters or possesses a forged or counterfeited writing], 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, namely _______________] [knowingly altered or possessed a forged or counterfeited writing, namely _______________]; and

2) The Defendant acted with intent [to deceive or harm the government or another person] [knowingly facilitated that deception or harm by another person].

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

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