The defendant is charged in [Count _______ of] the indictment with [[transporting] [shipping]] [[a stolen [specify firearm] [stolen ammunition]] in violation of Section 922(i) 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 [[transported] [shipped]] [[a stolen [specify firearm] [stolen specify ammunition]] [[from one state to another] [between a foreign nation and the United States]]; and
Second, the defendant knew or had reasonable cause to believe that the [specify firearm] [specify ammunition] had been stolen.
Revised May 2020