2133

Jury Instruction—Elements of 18 U.S.C. §  1956(a)(2)(B)(i)

There are four elements to Count __ of this indictment which the government must prove: FIRST, the defendant must knowingly transport, transmit, or transfer, or attempt to transport, transmit, or transfer [a] monetary instrument[s] or funds SECOND, from a place in the United States to or through a place outside the United States or to a place in the United States from or through a place outside the United States; THIRD, the defendant must know that the monetary instrument[s] or funds involved in the transportation, transmission, or transfer, or attempted transportation, transmission, or transfer, represent the proceeds of some of form unlawful activity; FOURTH, the defendant must know that the transportation, transmission, or transfer or attempted transportation, transmission, or transfer, is designed, in whole or in part, to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity. Title 18, U.S.C. § 1956(a)(2)(B)(i) Granted ____ Denied ____