DOJ-OGR-00008567.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 563** **Filed 12/18/21** **Page 29 of 167** **Instruction No. 19: Count Four: Transportation of an Individual Under the Age of 17 a Minor to Engage in Illegal Sexual Activity - The Elements** In order to prove the Defendant guilty of Count Four, the Government must establish each of the following three elements of the crime beyond a reasonable doubt: * First, that the Defendant knowingly transported an individual in interstate or foreign commerce, as alleged in the Indictment. * Second, that the Defendant transported the individual with the intent that she would engage in sexual activity for which any person can be charged with a criminal offense under New York law, as alleged in the Indictment; and * Third, that the Defendant knew that the individual was less than seventeen years old at the time of the acts alleged in Count Four of the Indictment. Count Four also relates solely to Jane during the time period 1994 to 1997.