9th Cir. Model Jury Instr. (Criminal) 24.15

The defendant is charged in [Count _______ of] the indictment with subornation of perjury in violation of Section 1622 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 voluntarily and intentionally persuaded [name of witness] to commit perjury;

Second, the defendant acted with the intent that [name of witness] would deceive the [court] [jury]; and

Third, [name of witness] committed perjury in that:

(a) [he] [she] testified under oath or affirmation at [describe proceeding] that [specify alleged false testimony];

(b) the testimony given was false[, with all of you agreeing at to which statement was false];

(c) at the time [name of witness] testified, [he] [she] knew the testimony was false; and

(d) the false testimony was material to the matter before the [court] [grand jury]; that is, the testimony had a natural tendency to influence, or was capable of influencing, the actions of [specify, for example: the grand jury].