9th Cir. Model Jury Instr. (Criminal) 20.27

The defendant is charged in [Count _______ of] the indictment with [transporting] [attempting to transport] a person with intent that the person engage in [prostitution] [criminal sexual activity] in violation of Section 2421 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, the defendant knowingly [transported] [attempted to transport] a person in [interstate SEQ CHAPTER \h \r 1commerce] [foreign commerce SEQ CHAPTER \h \r 1] [specify territory or possession of the United States]; [and]

Second, the defendant [transported] [attempted to transport] a person with the intent that such person engage in [prostitution] [describe criminal sexual activity] [.] [;] [; and]

[Third, that [if the sexual activity had occurred] [based upon the sexual activity that occurred], the defendant could have been charged with a criminal offense under the laws of [the United States] [insert the state or territory]. [In [state or territory], it is a criminal offense to [describe proposed sexual activity]] [.] [; and]]

SEQ CHAPTER \h \r 1[If the defendant is charged with attempt: [Third] [Fourth], the defendant did something that was a substantial step toward committing the crime. SEQ CHAPTER \h \r 1

A “substantial step” is conduct that strongly corroborated the defendant’s intent to commit the crime. To constitute a substantial step, a defendant’s act or actions must unequivocally demonstrate that the crime will take place unless interrupted by independent circumstances. Mere preparation is not a substantial step toward committing the crime.

Jurors do not need to agree unanimously as to which particular act or actions constituted a substantial step toward the commission of a crime.]

A defendant transports a person with the intent that such person engage in [prostitution] [describe criminal sexual activity] if the intended [prostitution] [describe criminal sexual activity] was a dominant, significant, or motivating purpose of the transportation.