2112. Jury Instruction -- Elements Of 18 U.S.C. § 1956(a)(1)(A)(i)

There are four elements to Count of this indictment which the government must prove:

FIRST, the defendant must knowingly conduct or attempt to conduct a financial transaction;

SECOND, the defendant must know that the property involved in the financial transaction represents the proceeds of some form of unlawful activity;

THIRD, the property involved in the financial transaction must, in fact, involve the proceeds of specified unlawful activity; and

FOURTH, the defendant must engage in the financial transaction with the intent to promote the carrying on of specified unlawful activity.

Title 18, U.S.C. § 1956(a)(1)(A)(i)

Granted ____

Denied ____