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10.1-4 Criminal Simulation -- § 53a-141 (a) (1)
Revised to December 1, 2007
The defendant is charged [in count __] with criminal simulation. The statute defining this offense reads in pertinent part as follows:
a person is guilty of criminal simulation when with intent to defraud, (he/she) makes or alters any object in such manner that it appears to have an antiquity, rarity, source or authorship which it does not in fact possess.
For you to find the defendant guilty of this charge, the state must prove the following elements beyond a reasonable doubt:
Element 1 - Made or altered an
object to falsify it
The first element is that the
defendant made or altered an object in such manner that it appeared to have an
antiquity, rarity, source or authorship that it did not in fact possess.
Simulation is the assumption of a false appearance. Criminal simulation is a
feigned or fictitious transaction to effect a fraud.
Element 2 - Intent to defraud
The second element is that the
defendant specifically intended to defraud another person. <See
Intent to Defraud, Instruction 2.3-6.>
Conclusion
In summary, the state must prove beyond a reasonable doubt that 1) the defendant made or altered <insert type of object and describe how it had been falsified>, and 2) (he/she) intended to defraud another person.
If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
criminal simulation, then you shall find the defendant guilty. On the other
hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.