UJI 14-1640 NMRA
UJI 14-1640. Fraud; essential elements.
For you to find the defendant guilty of fraud [as charged in Count __________]1, the
state must prove to your satisfaction beyond a reasonable doubt each of the following
elements of the crime:
1. The defendant, by any words or conduct, [made a promise defendant had no
intention of keeping] [misrepresented a fact]2 to __________________ (name of victim),
intending to deceive or cheat __________________ (name of victim);
2. Because of the [promise] [misrepresentation]2 and __________________’s
(name of victim) reliance on it, defendant obtained __________________ (describe
property or state amount of money);3
3. This __________________ (property) belonged to someone other than the
defendant;
[4. The __________________ (property) had a market value4 [of over $
__________;]5]
5. This happened in New Mexico on or about the __________ day of
______________, __________.