Does anyone have language they like when alleging credit card abuse when the card was presented to an ATM?

If so, would you mind sharing it?

"intentionally and knowingly with intent to fraudulently obtain property and services, use a credit card, to wit: (name card), with knowledge that the card had not been issued to him/her, the said defendant, and with knowledge that the said card was not used with the effective consent of the cardholder, cardholder name"

Hope this helps.