5th Cir. Pattern Jury Instr. (Criminal) 2.43E

18 U.S.C. §§ 922(j), 924(a)(2)

Title 18, United States Code, Sections 922(j) and 924(a)(2), make it a crime for anyone to

knowingly receive, possess, conceal, store, barter, sell, or dispose of any stolen firearm or stolen

ammunition, [pledge or accept as security for a loan any stolen firearm or stolen ammunition,]

which has been shipped or transported in interstate or foreign commerce [which is moving as,

which is a part of, or which constitutes interstate or foreign commerce], eithe r before or after it

was stolen, knowing or having re asonable cause to believe that the firearm or ammunition was

stolen.

For you 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: That the defendant knowingly possessed [received] [concealed] [stored] [bartered]

[sold] [disposed of] a stolen firearm [ammunition];

[First: That the defendant knowingly pledged [accepted as security for a loan] any stolen

firearm [ammunition]];

Second: That the defendant knew or had reasonable cause to believe that the firearm

[ammunition] was stolen; and

Third: That the firearm [ammunition] was moving as [was part of] [constituted] [had been

shipped or transported in] interstate or foreign commerce, either before or after it was stolen.

[The term “State” includes the District of Columbia, the Commonwealth of Puerto Rico,

and the possessions of the United States.]