DOJ-OGR-00008641.pdf

Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 103 of 167 1 Instruction No. 14: Count Two: Enticement to Engage in Illegal Sexual Activity - The Elements 2 3 To prove the Defendant guilty of Count Two, the Government must prove each of the 4 following three elements beyond a reasonable doubt: 5 First, that the Defendant knowingly persuaded or induced or enticed or coerced an 6 individual to travel in interstate commerce, as alleged in the Indictment; 7 Second, that the individual traveled in interstate commerce; and 8 Third, that the Defendant acted with the intent that the individual would engage in sexual 9 activity for which any person can be charged with a criminal offense under New York law, as 10 alleged in the Indictment. 11 Count Two relates solely to Jane during the time period 1994 to 1997. 20 DOJ-OGR-00008641