10th Cir. Crim. Pattern Jury Instr. 2.07

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

of 18 U.S.C. section 3.

This law makes it a crime for anyone, knowing that a crime

against the United States has been committed, to obstruct justice

by giving assistance to another person who committed that crime,

in order to hinder or prevent that person’s apprehension or

punishment. A person who does this is called an accessory after

the fact.

In this case, the defendant is not charged with actually

committing the crime of [—]. Instead, he is charged with helping

someone else try to avoid being arrested, prosecuted or punished

for that crime.

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: another person committed the crime of [———], which is

an offense against the United States;

Second: the defendant knew another person [—————] had

already committed the crime of [———].

Third: the defendant then helped that person try to avoid

being arrested, prosecuted or punished.

Fourth: the defendant did so with the intent to help that

person avoid being arrested, prosecuted or punished.