10th Cir. Crim. Pattern Jury Instr. 2.84

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

of 18 U.S.C. section 3146.

This law makes it a crime willfully to fail to [appear in court]

[surrender for service of sentence] on a required date.

To find the defendant guilty of this crime you must be

convinced that the government has proved each of the following

beyond a reasonable doubt:

First: the defendant was [charged with a crime punishable by

[state maximum punishment applicable to charged offense]]

[convicted of [name of crime]] in this court;

Second: the defendant had been released on [bond] [his own

recognizance] by a [specify judicial officer] on condition that the

defendant [appear in court] [surrender for service of sentence];

Third: the defendant thereafter willfully failed to [appear in

court] [surrender for service of sentence] as required.

Defendant would not have willfully failed to [appear]

[surrender] if (a) uncontrollable circumstances prevented

defendant from [appearing] [surrendering]; (b) the defendant did

not himself contribute to the creation of such circumstances in

reckless disregard of the requirement to [appear] [surrender]; and

(c) the defendant then [appeared] [surrendered] as soon as such

circumstances ceased to exist.