10th Cir. Crim. Pattern Jury Instr. 2.16

RIGHTS 18 U.S.C. § 241

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

of 18 U.S.C. section 241.

This law makes it a crime for two or more persons to conspire

to [injure] [oppress] [threaten] [intimidate] someone in the free

exercise or enjoyment of any right or privilege secured by the

Constitution or laws of the United States.

To find the defendant guilty of this crime you must be

convinced that the government has proved each of the following

beyond a reasonable doubt:

First: the defendant knowingly agreed with another to

[injure] [oppress] [threaten] [intimidate] one or more persons;

and

Second: in doing so, the defendant intended to [hinder]

[prevent] [interfere with] [name of person]’s exercise or enjoyment

of [his] [her] right [name right, e.g., to vote], which is a right

secured by the Constitution or laws of the United States.

[Third: include any statutory enhancement element, e.g.,

[name of person] died as a result of acts committed in furtherance

of the conspiracy.]

[The government need not prove that the defendant intended

for [name of person] to die. It must prove that [name of person]’s

death was a foreseeable result of the defendant’s conduct.]