UJI 14-1645. Insurance policies; false applications; essential elements.

For you to find the defendant guilty of making a false application, [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 made a false or fraudulent statement or representation as to any application for insurance [or] _________________ (describe other coverage); 2. The false statement or representation was material to the application for insurance which means the statement or representation had a natural tendency to influence the decision of __________________ (insert name of insurance company or other provider of coverage). 3. The defendant [knew the statement to be untrue]2 [acted with reckless disregard of the truth]; 4. This happened in New Mexico on or about the ______ day of __________________, ______.