THE GRAND JURY CHARGES:
- That at all times material to this Indictment (victim whose property was to be obtained) was engaged in (describe commercial activities) , in [interstate][foreign] commerce and an industry which affects [interstate][foreign] commerce.
- That on (date) in the ____________ District of ______________, and elsewhere, defendant, _________________, did unlawfully obstruct, delay and affect, and attempt to obstruct, delay and affect, commerce as that term is defined in Title 18, United States Code, Section 1951, and the movement of articles and commodities in such commerce, by robbery as that term is defined in Title 18, United States Code, Section 1951, in that the defendant ____________________ did unlawfully take and obtain personal property consisting of (describe tangible personal property) from [the person of][in the presence of] (owner or possessor of property) , against his/her will by means of actual and threatened force, violence, and fear of injury, immediate and future, to [his/her person][his/her property][property in his/her custody and possession][the person of a relative and member of his/her family][the property of _______________, a relative and member of his/her family], that is, (describe defendant's taking to obtaining by actual or threatened use of force, or fear of injury) .
All in violation of Title 18, United States Code, Section 1951.
[cited in JM 9-131.010]