|ICJI 420 FRAUD AND DECEIT (CONTROLLED SUBSTANCE)-DEFINED
As used in these instructions, the elements of fraud and deceit are as follows:
1. A statement of fact or presentation of a false document for the purpose of getting another party to act.
2. That fact must be untrue or document false.
3. The party making the statement must know or believe the fact to be untrue or document false.
4. The person to whom the statement was made or document presented must believe the statement or document to be true and rely upon it.
5. The statement or document must be material.