In order to be sufficient on its face, an information must provide reasonable cause to believe that the defendant has committed the crime charged and contain nonhearsay allegations that, if true, establish every element of the crime and its commission by the defendant (see CPL 100.40 [1] [b], [c]). Reasonable cause to believe that a person has committed an offense “exists when evidence or information which appears reliable discloses Facts or circumstances which are collectively of such weight and persuasiveness as to convince a person of ordinary intelligence, judgment and experience that it is reasonably likely that such offense was committed and that such person committed it” (CPL 70.10 [2]).
A person criminally possesses a forged instrument in the third degree when, “with knowledge that it is forged and with intent to defraud, deceive or injure another, he utters or possesses a forged instrument” (Penal Law §170.20). A forged instrument is “a written instrument which has been falsely made, completed or altered” (Penal Law §170.00 [7]).1 A person “falsely makes” a written instrument “when he makes or draws a…written instrument…which purports to be an authentic creation of its ostensible maker or drawer, but which is not such…because the ostensible maker or drawer…did not authorize the making or drawing thereof” (Penal Law §170.00 [4]).
