9th Cir. Model Jury Instr. (Criminal) 15.1

The defendant is charged in [Count ______ of] the indictment with producing without legal authority [an identification document] [an authentication feature] [a false identification document] in violation of Section 1028(a)(1) of Title 18 of the United States Code. For the defendant to be found guilty of that charge, the government must prove each of the following elements beyond a reasonable doubt:

First, the defendant knowingly produced [an identification document] [an authentication feature] [a false identification document];

Second, the defendant produced the [identification document] [authentication feature] [false identification document] without lawful authority; and

[Third, the [identification document] [authentication feature] [false identification document] was or appeared to be issued by or under authority of [the United States] [specify issuing authority].]

or

[Third, the production of the [identification document] [authentication feature] [false identification document] was in or affected commerce between one state and [an]other state[s], or between a state of the United States and a foreign country.]

or

[Third, in the course of production, the [identification document] [authentication feature] [false identification document] was transported in the mail.]