UJI 14-4302 NMRA
UJI 14-4302. Fraudulent practices; sale of securities; essential elements.
For you to find the defendant guilty of fraudulent practices [as charged in Count
__________],1 the State must prove beyond a reasonable doubt each of the following
elements of the crime:
1. The defendant [offered to sell] [sold] [offered to purchase] [or] [purchased]2 a
security;3
2. In connection with the [offer to sell] [sale] [offer to purchase] [or] [purchase]2 of
the security, the defendant purposely and directly or indirectly:
[used a plan or scheme to deceive or cheat others;]2
[OR]
[made an untrue statement of fact that under the circumstances would have been
important or significant to the investment decision of a reasonable person;]
[OR]
[OR]
[engaged in an act, practice or course of business which would cheat or would
operate as a fraud or deceit upon a reasonable person;]
3. This happened in New Mexico on or about the __________ day of
______________, __________.4