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10 11 Case 1:20-cr-00330-PAE Document562 - Filed 12/17/21 Page 21 of 82 Instruction No. 14: Count Two: Enticement to Engage in Illegal Sexual Activity — The Elements To prove the Defendant guilty of Count Two, the Government must prove each of the following three elements beyond a reasonable doubt: First, that the Defendant knowingly persuaded or induced or enticed or coerced an individual to travel in interstate commerce, as alleged in the Indictment; Second, that the individual traveled in interstate or foreign commerce; and Third, that the Defendant acted with the intent that the individual 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. Count Two relates to Jane during the time period 1994 to 1997. 20 DOJ-OGR-00008477