DOJ-OGR-00008561.jpg

10 ft Case 1:20-cr-00330-PAE Document563 _ Filed 12/18/21 Page 23 of 167 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 er-fereig¢a-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 solely to Jane during the time period 1994 to 1997. 22 DOJ-OGR-00008561