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10 11 12 Case 1:20-cr-00330-PAE Document562_ Filed 12/17/21 Page 27 of 82 Instruction No. 19: Count Four: Transportation of 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 to Jane during the time period 1994 to 1997. 26 DOJ-OGR-00008483