11th Cir. Pattern Jury Instr. (Criminal) O60.1

(First and Second Paragraphs)

It’s a federal crime to knowingly and willfully [use] [attempt to use] a

passport issued or designed for the use of another [in violation of the conditions or

restrictions contained in the passport] [in violation of the rules pursuant to the laws

regulating the issuance of passports].

The Defendant can be found guilty of this crime only if all the following

facts are proved beyond a reasonable doubt:

(1) the Defendant [used] [attempted to use] a passport;

(2) [the passport was issued or designed for the use of someone other

than the defendant] [the use or attempted use violated the conditions

or restrictions contained in the passport] [the use or attempted use

violated the rules governing the issuance of passports];

(3) the Defendant acted knowingly and willfully[.] [and]

[(4) the Defendant did so [to facilitate an act of international

terrorism] [to facilitate a drug-trafficking crime].]

[To “facilitate” an act simply means to help or further the

accomplishment of that act.]

[An “act of international terrorism” means (1) a criminal

act that is dangerous to human life, (2) appears to be

intended to intimidate or coerce a civilian population, or

to influence the policy of a government by intimidation

or coercion, or to affect the conduct of a government by

assassination or kidnapping, and (3) occurs outside the

United States or transcends national boundaries in terms

of the means by which it is accomplished, the persons

intended to be intimidated or coerced, or the locale in

which the perpetrator operates or seeks asylum.]

[A “drug-trafficking crime” means any felony punishable

under the Controlled Substances Act, 21 U.S.C. § 801 et

seq., the Controlled Substances Import and Export Act,

21 U.S.C. 951 et seq., or chapter 705 of title 46 of the

United States Code.]