The state accuses the defendant of having committed the offense of forgery.

Relevant Statutes

A person commits the offense of forgery if the person [makes/alters/executes/completes/authenticates] a writing so that it purports to [be/have been] [the act of another who did not authorize that act/executed at a time or place or in a numbered sequence other than was in fact the case/a copy of an original when no such original existed] with the intent to defraud or harm another.

Definitions

Another

“Another” means a person other than the actor.

Actor

“Actor” means a person whose criminal responsibility is in issue in a criminal action.

Harm

“Harm” means anything reasonably regarded as loss, disadvantage, or injury, including harm to another person in whose welfare the person affected is interested.

Writing

A writing includes (1) a printing or any other method of recording information; (2) money, coins, tokens, stamps, seals, credit cards, badges, and trademarks; or (3) symbols of value, right, privilege, or identification.

Intending to Defraud or Harm Another

A person intends to defraud or harm another if it is the person’s conscious objective or desire to defraud or harm another.

Application of Law to Facts

You must determine whether the state has proved, beyond a reasonable doubt, [five/six] elements. The elements are that—

1. the defendant, in [county] County, Texas, on or about [date], [insert specific allegations, e.g., altered, made, or executed] a [describe the alleged writing, e.g., baseball with a forged signature];

2. [describe alleged writing] was a writing;

3. the defendant did this so that it appeared to be the act of [name];

4. [name] did not authorize the act; [and]

5. the defendant did this with the intent to defraud or harm [name][./; and]

[Include the following if applicable.]

6. the defendant did this to obtain property or a service in an amount of [insert appropriate dollar range from Tex. Penal Code § 32.21(e–1)].

You must all agree on elements 1, 2, 3, 4, [and 5/5, and 6] listed above.

If you all agree the state has failed to prove, beyond a reasonable doubt, one or more of elements 1, 2, 3, 4, [and 5/5, and 6] above, you must find the defendant “not guilty.”

If you all agree the state has proved, beyond a reasonable doubt, elements 1, 2, 3, 4, [and 5/5, and 6] listed above, you must find the defendant “guilty.”

[Insert any other instructions raised by the evidence. Then continue with the verdict form found in CPJC CPJC2.1, the general charge.]