5th Cir. Pattern Jury Instr. (Criminal) 2.65A

18 U.S.C. § 1542 (FIRST PARAGRAPH)

Title 18, United States Code, Section 1542, makes it a crime to willfully and knowingly

make a false statement in an application for a passport with intent to induce or secure the issuance

of a passport under the authority of the United States, either for his [her] own use or the use of

another, contrary to the laws regulating the issuance of passports or the rules prescribed pursuant

to such laws.

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 made a false statement in an application for a United States

passport;

Second: That the defendant made the statement intending to get a United States passport

for his [her] own use [someone else’s use]; and

Third: That the defendant acted willfully and knowingly.

[Fourth: That the defendant did so to facilitate an act of international terrorism [to facilitate

a drug trafficking crime].]

A statement is false if it was untrue when made, and the person making it knows it is untrue.

[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 violent or 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 mass destruction, assassination or kidnapping, and (3) occurs primarily outside the United

States or transcends national boundar ies 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, the Controlled Substances Import and Export Act, or the Maritime Drug Enforcement Act.]