10th Cir. Crim. Pattern Jury Instr. 2.78

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

of 18 U.S.C. section 2113(b).

This law makes it a crime to take and carry away, with intent

to steal, any property or money or any other thing of value

exceeding $1,000 belonging to or in the care, custody, control,

management, or possession of any federally insured bank.

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 took and carried away [money] [property]

[a thing of value], [belonging to] [in the care, custody, control,

management, or possession of] [insert name of bank];

Second: at that time [insert name of bank] had its deposits

insured by the Federal Deposit Insurance Corporation;

Third: the defendant took and carried away such [money]

[property] [thing of value] with the intent to steal; and

Fourth: such [money] [property] [thing of value] exceeded

$1,000 in value.