5th Cir. Pattern Jury Instr. (Criminal) 2.66

18 U.S.C. § 1544 (FIRST AND SECOND PARAGRAPHS)

Title 18, United States Code, Section 1544, makes it a crime for anyone willfully and

knowingly to 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 viol ation of the rules governing the

issuance of passports].

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] a passport;

Second: That the passport was issued or designed for the use of someone other than the

defendant [that the use or attempted use violated the conditions or restrictions contained in the

passport] [that the use or attempted use violated the rules governing the issuance of passports]; and

Third: That the defendant used [attempted to use] the passport willfully and knowingly,

that is, deliberately, voluntarily, and knowing that the passport was issued or designed for the use

of someone other than the defendant [with the intent to violate the conditions or restrictions

contained in the passport] [with the intent to violate the rules governing the issuance of passports].

[Fourth: That the defendant used [attempted to use] the passport to facilitate an act of

international terrorism [a drug trafficking crime].]