17.1 FORGERY 831.01, Fla. Stat. To prove the crime of Forgery, the State must prove the following two elements beyond a reasonable doubt: 1. [Name of defendant] falsely made, altered, forged, or counterfeited a [document named in charge]. 2. [Name of defendant] intended to injure or defraud some person or firm. It is not necessary that [name of defendant] intended to use the ent named [document nam or to profit from its use. It is sufficient if ed [name of defendant] intended that some person would use it to injure or defraud. Nor is it necessary to prove what person [name of defendant] intended to be injured or defrauded if [name of defendant] did intend that some person would be injured or defrauded.