10th Cir. Crim. Pattern Jury Instr. 2.02

(Bringing in—not port of entry)

The defendant is charged in count ————— with a violation

of 8 U.S.C. section 1324(a)(1)(A)(i).

This law makes it a crime to bring an alien into the United

States at a place other than a designated port of entry. An alien is

a person who is not a citizen or national of the United States.

T o fi n d t h e d e f e n d a n t g u i l t y o f t h i s c r i m e y o u m u s t b e

convinced that the government has proved each of the following

beyond a reasonable doubt:

First: the defendant [brought] [attempted to bring] an alien

into the United States;

Second: that entry was [attempted] at a place other than a

designated port of entry;

Third: the defendant knew at the time of the [attempted]

[entry] that the person was an alien.