If D does NOT present (show) or use or tender the card in any way, but on arrest for one thing, officer finds fake card in D's wallet. I don't think that files under PC 37.10(a)(2) since D does not present or use it - he just possesses it, so how would you charge this?
I couldn't find any guidance under case law and dictionary definitions of "make", "present", and "use" don't improve my opinion of pleading under tampering. Suggestions?