3d Cir. Model Jury Instr. (Criminal) 2.13

by a Convicted Felon (18 U.S.C.A. § 922(g))

You have heard evidence (through a stipulation) that the defendant was

convicted before this incident in (name of court; e.g., a court of the

Commonwealth of Pennsylvania) of a crime punishable by imprisonment for a

term exceeding one year.

This prior conviction has been brought to your attention only because

it tends to establish one of the elements of the crime of possession of a firearm

by a convicted felon as set forth in the indictment, specifically, that the

defendant had a prior felony conviction. You are not to speculate as to the

nature of the conviction. You may not consider the prior conviction in

deciding whether (name of defendant) was in knowing possession of the gun

that (he)(she) is charged in this case with possessing, which is a disputed issue

in this case.

The fact that the defendant was found guilty of another crime on

another occasion does not mean that (he)(she) committed this crime on (date

of offense charged in indictment), and you must not use (his)(her) guilt of the

other crime as proof of the crime charged in this case except for the one

element of this crime which I have mentioned. You may find the defendant

guilty of this crime only if the government has proved beyond a reasonable

doubt all of the elements of this crime and that the defendant committed it.