10th Cir. Crim. Pattern Jury Instr. 2.39

18 U.S.C. § 911

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

of 18 U.S.C. section 911.

This law makes it a crime for anyone falsely and willfully to

represent oneself to be a citizen 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 stated he was a citizen of the United

States;

Second: the defendant was not a citizen of the United States

at that time; and

Third: the defendant knew he was not a citizen and

deliberately made this false statement with intent to disobey or

disregard the law.