A person who, with intent to deceive or harm the government or another person [or with knowledge that he is facilitating such a deception or harm by another person,] knowingly issues a writing without authority to issue it, or knowingly utters or possesses a deceptive writing, is guilty of Deceptive Writing.

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 [issued a writing without authority to issue it] [or] [uttered or possessed a deceptive writing]; and

2) The Defendant [intended to deceive or harm the government or [_______________] [another person]] [knowingly facilitated a deception or harm by _______________] [.] [; and] [

3) The offense was committed pursuant to a scheme to defraud [_______________] [another person], [or others] of money or property of a value in excess of ten thousand dollars.] [

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

[5) The offense was committed pursuant to a scheme to defraud [_______________,] [another person] [or others] of money or property of a value in excess of one hundred dollars.]

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

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