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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Count Two: Enticement to Engage in Illegal Sexual Activity —- Second Element The second element of Count Two which the government must prove beyond a reasonable doubt is that the+ndhdual[Jane Doe-1 pseudonym] traveled in interstate commerce_ from Florida to New York, as alleged in the Indictment. As I just stated, “interstate commerce” simply means movement between one state and another. Adapted from Sand et al., Modern Federal Jury Instructions, Instr. 64-8. 21 Page 21 of 93 DOJ-OGR-00006087