UJI 14-1646. Insurance; false claims or proof of loss; essential elements.

For you to find the defendant guilty of making a [false claim]1 [false proof of loss]1 [as charged in Count ________]2, the state must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime: 1. The defendant [presented]3 [or] [caused to be presented] [a false or fraudulent claim]1 [any proof in support of a false or fraudulent claim for payment of loss under an insurance policy]; 2. The [claim] [proof in support of a claim for payment] was made for the purpose of obtaining any money or benefit; 3. The defendant [knew the statement to be untrue]2 [or] [acted with reckless disregard of the truth]; 4. This happened in New Mexico on or about the ______ day of __________________, ______.