UJI 14-1648. Insurance; false statement or representation; essential elements.

For you to find the defendant guilty of making a false statement or representation relative to an insurance policy [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 [on an application for an insurance policy] [or] [relative to an application for an insurance policy]; 2. The statement or representation was made for the purpose of obtaining any fee, commission or benefit from an insurer, agent, broker or individual; 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 __________________, ______.