10th Cir. Crim. Pattern Jury Instr. 2.43

18 U.S.C. § 922(d)

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

of 18 U.S.C. section 922(d).

This law makes it a crime for a person knowingly to sell or

otherwise dispose of a firearm to [a person in a prohibited

category, e.g., a convicted felon] when the seller knows or has

reasonable cause to believe that such a person is [a member of a

prohibited category, e.g., a convicted felon].

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: t h e d e f e n d a n t k n o w i n g l y s o l d a fi r e a r m t o [name of

person];

Second: at the time of the sale, [name of person] was [a person

in a prohibited category, e.g., a convicted felon]; and

Third: at the time of sale, the defendant knew or had

reasonable cause to believe that [name of person] was [a person in

a prohibited category, e.g., a convicted felon].

The term “firearm” means any weapon that will or is designed

to or may readily be converted to expel a projectile by the action of

an explosive. The term “firearm” also includes the frame or

receiver of any such weapon, or any firearm muffler or firearm

silencer, or destructive device.