10th Cir. Crim. Pattern Jury Instr. 2.76.1

ORGANIZATIONS ACT—“SECTION C”

Elements of the Offense

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: an enterprise existed as alleged in the indictment;

Second: the enterprise affected interstate or foreign

commerce;

Third: the defendant was associated with or employed by the

enterprise;

Fourth: the defendant engaged in a pattern of racketeering

activity (or the collection of an unlawful debt); and

Fifth: the defendant conducted, or participated in the conduct

of, the enterprise through [that pattern of racketeering activity]

[collection of an unlawful debt].