At home without code book.

Minimum facts

Offense is forgery
Same victim
Checks written/cashed on different dates and at different locations

Is stacking available?

not if all the forgeries are in one indictment

They will be separate indictments, thanks

Separate indictment, separate dates, no problem.

But only if the convictions are obtained through separate trials or by agreed punishments. For more details, see pages 31-34, The Perfect Plea.

I had always copied the returned or forged check onto my indictment but now the crook is getting the check back at the store and so we don't have it. How are you changing your indictment?

I use the following language in check forgery cases:

then and there, with intent to defraud or harm another, pass to ________ a forged writing, knowing such writing to be forged, and such writing had been so completed that it purported to the act of ____________, who did not authorize the act, and said writing was a check.

No one has ever filed a motion to quash.

We used to copy the check onto the indictment as well. Now, we just reference the check number and bank. Again, no one has ever filed a motion to quash.