The defendant is charged in [Count _______ of] the indictment with obstruction of justice in violation of Section 1503 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, [name of juror] was a [grand] juror [who assented to a [verdict] [indictment]]; and
Second, the defendant injured [name of juror] [or [his] [her] property] on account of [his] [her] having [been] [assented to the [verdict] [indictment] as] a [grand] juror.
Comment
See Comment to Instruction 19.1 (Obstruction of Justice—Influencing Juror (18 U.S.C. § 1503)).