4.18.1546 False Statements in Document Required by Immigration Law,

18 U.S.C. § 1546(a) See Statute

[Defendant] is charged with making a false statement under oath in a document required by federal immigration laws. It is against federal law to make a false statement under oath in a document required by federal immigration laws. For you to find [defendant] guilty of this crime, you must be convinced that the government has proven each of these things beyond a reasonable doubt:

First, that [defendant] knowingly made a material false statement under oath;

Second, that [defendant] made the statement voluntarily and intentionally; and

Third, that [defendant] made the statement in an immigration form [identify number and title of document].

A false statement is made “knowingly” if [defendant] knew that it was false or demonstrated a reckless disregard for the truth with a conscious purpose to avoid learning the truth.

The statement is “material” if it has a natural tendency to influence or to be capable of influencing the decision of the decisionmaker to which it was addressed.

A statement is “false” if it is untrue when made.