10th Cir. Crim. Pattern Jury Instr. 2.79

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

of 18 U.S.C. section 2119.

This law makes it a crime to [take] [attempt to take] from [a

person] [the presence of another person] by [force and violence]

[intimidation] a motor vehicle that has moved in interstate

commerce.

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] [attempted to take] a [describe

motor vehicle as in indictment] from [a person] [the presence of

another person];

Second: the defendant did so by means of [force and violence]

[intimidation];

Third: the motor vehicle had been [transported] [shipped]

[received] in [interstate] [foreign] commerce;

[Fourth: the defendant intended to cause death or serious

bodily harm; and]

[Fifth: someone [suffered serious bodily injury] [died] as a

result of the crime.]

[“Serious bodily injury” means injury that involves a

substantial risk of death; extreme physical pain; protracted and

obvious disfigurement; or protracted loss or impairment of the

function of a bodily member, organ, or mental faculty].