9th Cir. Model Jury Instr. (Criminal) 23.1

The defendant is charged in [Count _______ of] the indictment with theft of government [money] [property] in violation of Section 641 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 [[embezzled] [stole] [converted to the defendant’s use] [converted to the use of another]] [money] [property of value] with the intention of depriving the owner of the use or benefit of the [money] [property];

Second, the [money] [property] belonged to the United States; and

Third, the value of the [money] [property] was more than $1,000.