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3.01. Consider Instructions as a Whole (10/8/12). 3.02. Presumption of Innocence; Reasonable Doubt (6/29/00). 3.03. Consider Only the Evidence (9/4/09). INSTRUCTION NO. 8.1: DAMAGE INSTRUCTIONS – FOR GUIDANCE ONLY. INSTRUCTION NO. 8.2: SPECIAL DAMAGES DEFINED. INSTRUCTION NO. 8.3: GENERAL DAMAGES DEFINED.Hawaii Jury Instruction - Counterfeit - Possession with Intent to Defraud. Download legal document templates from the largest catalogue of legal forms. § 708-852 Forgery in the second degree. (1) A person commits the offense of forgery in the second degree if, with intent to defraud, the person falsely ... Thus, the purpose of this work, Pattern Criminal Instructions for Criminal. Cases District of South Carolina, is to fill that void by publishing pattern ... The jury need not be bothered with an instruction on a lesser included offense unless there is a rational basis in the evidence for a verdict acquitting the ... First, a scheme, substantially as charged in the indictment, to defraud a financial institution [or to obtain a financial institution's money by means of false ... Use this instruction for possessing, offering or disposing of a forged instrument, which is only one of the ways of committing forgery. For an instruction based ... 2d 406 (1993). Mere possession of a forged instrument is not sufficient to establish an intent to injure or defraud. State v. Vasquez, 178 Wn. Forgery. (1) A person is guilty of forgery if, with intent to injure or defraud: (a) He or she falsely makes, completes, or alters a written instrument or;.