8.114 KIDNAPPING—INTERSTATE TRANSPORTATION (18 U.S.C. § 1201(a)(1))
The defendant is charged in [Count _______ of] the indictment with kidnapping in violation of Section 1201(a)(1) of Title 18 of the United States Code. In order 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 [[kidnapped] [seized] [confined]] [name of kidnapped person];
Second, the defendant held [name of kidnapped person] for ransom, reward or other benefit; and
Third, the defendant intentionally transported [name of kidnapped person] across state lines.