9th Cir. Model Jury Instr. (Criminal) 20.19

The defendant is charged in [Count _______ of] the indictment with sexual exploitation of a child in violation of Section 2251(b) of Title 18 of the United States Code. For the defendant to be found guilty of that charge, the government must prove each of the following elements beyond a reasonable doubt:

First, at the time, [name of victim] was under the age of eighteen years;

Second, the defendant was a [parent] [legal guardian] [person having custody or control] of [name of victim];

Third, the defendant knowingly permitted [name of victim] to [engage in sexually explicit conduct] [assist any other person to engage in sexually explicit conduct] for the purpose of producing a visual depiction of such conduct; and

Fourth,

[the defendant knew or had reason to know that the visual depiction would be mailed or transported across state lines or in foreign commerce.]

or

[the visual depiction was produced using materials that had been mailed, shipped, or transported across state lines or in foreign commerce.]

or

[the visual depiction was actually mailed or transported across state lines or in foreign commerce.]

or

[the visual depiction affected interstate commerce.]

The term “custody or control” includes temporary supervision over or responsibility for a minor, whether legally or illegally obtained.

In this case, “sexually explicit conduct” means [specify statutory definition].

In this case, “producing” means [specify statutory definition].

In this case, “visual depiction” means [specify statutory definition].