10th Cir. Crim. Pattern Jury Instr. 2.48

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

of 18 U.S.C. section 1014.

This law makes it a crime to knowingly make a false

statement to a federally insured bank for the purpose of

influencing the bank to make a loan.

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: [name bank] was federally insured;

Second: the defendant made a false statement to [name bank];

Third: the defendant knew the statement was false when he

made it; and

Fourth: the defendant intended to influence the bank to

[describe purpose as stated in indictment].

It is not necessary, however, to prove that the institution

involved was in fact influenced or misled.

To make a false statement to a federally insured bank, the

defendant need not directly submit the false statement to the

institution. It is sufficient that defendant submit the statement to

a third party, knowing that the third party will submit the false

statement to the federally insured bank.

A statement may be spoken, written, or made by other

conduct that communicates a fact to another person.