10th Cir. Crim. Pattern Jury Instr. 2.34

STOLEN FROM INTERSTATE SHIPMENT 18 U.S.C. § 659

(PARAGRAPH TWO)

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

of 18 U.S.C. section 659.

This law makes it a crime to [buy] [receive] [possess] goods

stolen from interstate commerce.

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 goods described in the indictment were in

defendant’s possession;

Second: the goods described in the indictment [were part of]

[were moving in] interstate or foreign commerce at the time the

goods were stolen;

Third: the defendant knew those goods were stolen;

and

Fourth: such property had a value of $1,000 or more.