10th Cir. Crim. Pattern Jury Instr. 2.83

18 U.S.C. § 2315 (FIRST PARAGRAPH)

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

of 18 U.S.C. section 2315.

This law makes it a crime for anyone to knowingly [receive]

[possess] [conceal] [store] [barter] [dispose of] stolen property

which has a value of $5,000 or more and which has crossed a

[state] [United States] boundary after being [stolen] [taken]

[unlawfully converted].

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 the government has proved each of the following beyond

a reasonable doubt:

First: the defendant [received] [possessed] [concealed-

][stored] [bartered] [sold] [disposed of] items of [stolen] [taken]

[unlawfully converted] property as described in the indictment;

Second: such items had crossed a [state] [United States]

boundary after having been [stolen] [unlawfully converted]

[unlawfully taken];

Third: the defendant knew the property had been [stolen]

[unlawfully converted] [unlawfully taken]; and

Fourth: such items had a value in excess of $5,000.