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

18 U.S.C. § 1542 (SECOND PARAGRAPH)

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

[use] [attempt to use] [furnish to another for use] any passport the issue of which was secured in

any way by reason of any false statement.

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 used [attempted to use] [furnished to another] any passport the

use of which was secured in any way by reason of any false statement; and

Second: That the defendant acted willfully and knowingly.

[Third: 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 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, the Controlled Substances Import and Export Act, or the Maritime Drug Enforcement Act.]