8.191 TRANSPORTATION FOR PROSTITUTION (18 U.S.C. § 2421)
The defendant is charged in [Count _______ of] the indictment with [transporting] [attempting to transport] a person with intent that the person engage in prostitution in violation of Section 2421 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 knowingly [transported] [attempted to transport] a person in [interstate] [foreign] commerce; [and]
Second, the defendant [transported] [attempted to transport] a person with the intent that such person engage in [prostitution] [any sexual activity for which a person can be charged with a criminal offense][.] [; and]
[Third, the defendant did something that was a substantial step toward committing the crime.
Mere preparation is not a substantial step toward committing the crime. To constitute a substantial step, a defendant’s act or actions must demonstrate that the crime will take place unless interrupted by independent circumstances.]
For an attempt to commit 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. United States v. Hofus, 598 F.3d 1171, 1176 (9th Cir.2010).