A DA's office has received a report of a particularly nasty false report of child abuse involving CPS employees, but they've never been presented with one of these cases before. The statute (below) is pretty straight-forward, but they were wondering if anyone else had already invented the wheel on charging this crime; if so, would you share your indictment language (and jury charge, if it went that far) with me so that I can pass it along to them? My email address is in my profile.

-Shannon

Family Code Sec. 261.107. FALSE REPORT; CRIMINAL PENALTY; CIVIL PENALTY. (a) A person commits an offense if, with the intent to deceive, the person knowingly makes a report as provided in this chapter that is false. An offense under this subsection is a state jail felony unless it is shown on the trial of the offense that the person has previously been convicted under this section, in which case the offense is a felony of the third degree.