6.18.922G-1 Felon In Possession of Firearm (18 U.S.C. § 922(g)) (bifurcated proceeding) Alternative 1: Bifurcation as to prior conviction only. Instruction to be included in first phase of trial: In addition to your verdict on Count(s) (No.(s) of the other counts of the the verdict form asks you to answer two special interrogatories or indictment) questions. Those two questions are: One, did the defendant, on or about knowingly possess (name), (date), (describe firearm charged in the indictment)? and Two, did the defendant, possess that firearm in or affecting interstate (name), or foreign commerce, as defined in these instructions? Please be aware that, after you complete your deliberations, there may be some additional evidence presented and an additional matter about which you will have to deliberate. Instruction to be given after the jury completes initial deliberations if, but only if, the jury answers both special interrogatories in the affirmative: Now that you have completed your initial deliberations, there is one additional matter for you to consider: Count of the indictment. Count of (No.) (No.) the indictment charges the defendant with being a felon in possession of a (name) firearm, which is a violation of federal law.
6.18.922G-1 Felon In Possession of Firearm (18 U.S.C. § 922(g)) (bifurcated proceeding) Alternative 1: Bifurcation as to prior conviction only. Instruction to be included in first phase of trial: In addition to your verdict on Count(s) (No.(s) of the other counts of the indictment) the verdict form asks you to answer two special interrogatories or questions. Those two questions are: One, did the defendant, (name), on or about (date), knowingly possess (describe firearm charged in the indictment)? and Two, did the defendant, (name), possess that firearm in or affecting interstate or foreign commerce, as defined in these instructions? Please be aware that, after you complete your deliberations, there may be some additional evidence presented and an additional matter about which you will have to deliberate. Instruction to be given after the jury completes initial deliberations if, but only if, the jury answers both special interrogatories in the affirmative: Now that you have completed your initial deliberations, there is one additional matter for you to consider: Count (No.) of the indictment. Count (No.) of the indictment charges the defendant (name) with being a felon in possession of a firearm, which is a violation of federal law.