10th Cir. Crim. Pattern Jury Instr. 2.55

The defendant is charged in count _________ with a violation

of 18 U.S.C. section 1201(a)(1).

This law makes it a crime to kidnap another person in

connection with interstate commerce.

To find the defendant guilty of this crime you must be

convinced that the government has proved each of the following

beyond a reasonable doubt:

First: the defendant, knowingly and unlawfully, [seized]

[confined] [inveigled] [kidnapped] [abducted] [carried away] [the

person described in the indictment];

Second: the defendant held [the person described in the

indictment] against his will for an appreciable period of time;

Third: the defendant did so for some purpose or benefit;

Fourth: [the defendant willfully transported [the person

described in the indictment] and that transportation was in

interstate [foreign] commerce] [the defendant traveled in

interstate [foreign] commerce in committing or in furtherance of

the offense] [the defe ndant used the mail or any means, facility,

or instrumentality of interstate [foreign] commerce in committing

or in furtherance of the offense].

Involuntariness or coercion in connection with the victim’s

detention is an essential part of the offense. [Additionally, an

appreciable period of time is time beyond that required to commit

a related offense, here [describe relevant offense(s)].]

[To “inveigle” a person means to lure, or entice, or lead the

person astray by false representations or promises, or other

deceitful means.]

[The term “willfully” means that the defendant acted

voluntarily and with the intent to violate the law.]