UJI 14-3122 NMRA
UJI 14-3122. Counterfeit substance; possession with intent to deliver; essential elements.
For you to find the defendant guilty of “possession with intent to deliver a counterfeit
substance” [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 possessed3 a drug called __________________2;
2. The defendant knew the substance was __________________2 [or believed it to
be __________________2]4 [or believed it to be some drug or other substance the
possession of which is regulated or prohibited by law];
3. The __________________2 had an unauthorized __________________5 which
falsely represented its manufacturer, distributor, or dispenser;
4. The defendant knew that the use of the __________________5 was
unauthorized;
5. The defendant intended to transfer the __________________2 to another;
6. This happened in New Mexico on or about the __________ day of
______________, __________.