Texas PJC Malpractice 2022

J OINT AND S EVERAL L IABILITY

PJC 72.9

PJC 72.9

Question and Instructions—Forgery as a Ground for Joint and Several Liability (Tex. Civ. Prac. & Rem. Code § 33.013(b)(2)(H))

QUESTION ______ Did Don Davis , with the specific intent to do harm to others, act in concert with [ name(s) of person(s) or entity(ies) with whom or with which Don Davis acted in concert ] to commit forgery that was a proximate cause of the damages, if any, to Paul Payne ? Don Davis acts with specific intent to do harm with respect to the nature of Don Davis ’s conduct and the result of [ name(s) of person(s) or entity(ies) with whom or with which Don Davis acted in concert ]’s conduct when it is [ name(s) of person(s) or entity(ies) with whom or with which Don Davis acted in con cert ]’s conscious effort or desire to engage in the conduct for the purpose of doing substantial harm to others. “Forge” means— 1. to alter, make, complete, execute, or authenticate any writing so that it purports— a. to be the act of another who did not authorize that act; or b. to have been executed at a time or place or in a numbered sequence other than was in fact the case; or c. to be a copy of an original when no such original existed; or 2. to issue, transfer, register the transfer of, pass, publish, or otherwise utter a writing that is forged within the meaning of paragraph 1; or 3. to possess a writing that is forged within the meaning of paragraph 1 with intent to utter it in a manner specified in paragraph 2. “Writing” includes— 1. printing or any other method of recording information; and 2. money, coins, tokens, stamps, seals, credit cards, badges, and trade marks; and 3. symbols of value, right, privilege, or identification. A person commits an offense if he forges a writing with intent to defraud or harm another.

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