17.1 FORGERY
§ 831.01, Fla. Stat.
To prove the crime of Forgery, the State must prove the following two elements beyond a reasonable doubt:
1.	(Defendant) falsely [made] [altered] [forged] [counterfeited] a (document named in charge).
2.	(Defendant) intended to injure or defraud some person or firm.
It is not necessary that the defendant intended to use (document named in charge) [himself] [herself] or to profit [himself] [herself] from its use. It is sufficient if [he] [she] intended that some person would use it to injure or defraud.
Give if victim not named.
Nor is it necessary to prove what person the defendant intended to be injured or defrauded if [he] [she] did intend that some person would be injured or defrauded.
Lesser Included Offenses
FORGERY — 831.01
CATEGORY ONE	CATEGORY TWO	FLA. STAT.	INS. NO.	
None				
	Attempt	777.04(1)	5.1	
Comment
This instruction was adopted in 1981.