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Case 1:20-cr-00330-PAE Document 767 _ Filed 08/10/22 Page 205 of 257 3039 LCKVMAX8 Charge 1 individual under the age of 18. Statute. 2 The relevant statute for Count Six is Title 18, United 3 States Code, Section 1591, which provides, in pertinent part, 4 that: "Whoever knowingly, in or affecting interstate commerce, 5 recruits, entices, harbors, transports, provides, or obtains by 6 any means a person, knowing that the person has not attained 7 the age of 18 years and will be caused to engage ina 8 commercial sex act" is guilty of a crime. 9 Instruction No. 25. Count Six. Sex trafficking of an 10 individual under the age of 18. The elements. 11 To find the defendant guilty of Count Six, the 12 government must prove each of the following four elements 13 beyond a reasonable doubt: 14 First, the defendant knowingly recruited, enticed, 15 harbored, transported, provided, or obtained a person. 16 Second, the defendant knew that the person was under 17 the age of 18 years. 18 Third, the defendant knew that the person would be 19 caused to engage in a commercial sex act. 20 And fourth, the defendant's acts were in or affecting 2] interstate commerce. 22 The count relates solely to Carolyn during the time 23 period 2001 to 2004. 24 Instruction No. 26. Count Six. Sex trafficking of an 25 individual under the age of 18. First element. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014605