10th Cir. Crim. Pattern Jury Instr. 2.24.1

OF COUNTERFEIT OBLIGATIONS OR SECURITIES

18 U.S.C. § 472

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

of 18 U.S.C. section 472.

This law makes it a crime to, with intent to defraud, bring into

the United States, or keep in possession or conceal, any falsely

made, forged, counterfeited, or altered obligation or other security

of the United States.

[Name security or obligation] is an obligation or security of

the United States within the meaning of that law.

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 into the United States] [kept in

his possession] [concealed], [falsely made] [forged] [counterfeit]

[altered] [name obligation or security];

Second: the defendant knew that the [name obligation or

security] was [falsely made] [forged] [counterfeit] [altered];

and

Third: the defendant did so with intent to defraud.

An item is “counterfeit” if it bears such a likeness to a genuine

item as is calculated to deceive an unsuspecting person of ordinary

observation and care.

To act with “intent to defraud” means to act with intent to

cheat or deceive. It does not matter, however, whether anyone was

in fact cheated or deceived.