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 ______________ the 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 extortion, as that term is defined in Title 18, United States Code, Section 1951, in that the defendant ____________ did obtain and attempt to obtain (tangible or intangible property) the property of (victim with connection to commerce) with his/her consent having been induced by the wrongful use of actual and threatened force, violence and fear, [including fear of economic harm,] in that the defendant did (describe defendant's wrongful use of force, violence or fear) .
All in violation of Title 18, United States Code, Section 1951.
** See United States v. Enmons, 410 U.S. 396 (1973), holding that violence undertaken by the parties to labor-management relations is "wrongful" only if they have no legitimate claim under the federal labor laws to the wages, benefits, and other property which they seek to obtain.