As with the mail and wire fraud statutes, each use of the interstate facility or mail in furtherance of the bribery scheme is a separate offense. United States v. Jabara, 644 F.2d 574, 577–78 (6th Cir. 1981). The defendant need not actually have used the facility or mail, so long as it was a reasonably foreseeable consequence of his or her activities. United States v. Kelley, 395 F.2d 727, 729 (2d Cir. 1968). Nor need the jurisdictional act have in itself constituted the illegal activity, as long as it promoted it in some way. United States v. Welch, 327 F.3d 1081, 1092 (10th Cir. 2003); United States v. Bagnariol, 665 F.2d 877, 898–99 (9th Cir. 1981); United States v. Peskin, 527 F.2d 71, 79 n.3 (7th Cir. 1975); McIntosh v. United States, 385 F.2d 274, 276 (8th Cir. 1967). An unusual feature of the Travel Act is that it requires an overt act subsequent to the jurisdictional event charged in the indictment. Thus, if a Travel Act charge is predicated on a use of the mails, the government must allege and prove that the defendant subsequently acted to further the underlying unlawful activity. The subsequent overt act need not be unlawful in itself; this element has been generally held to be satisfied by the commission of a legal act as long as the act facilitated the unlawful activity. See, e.g., United States v. Davis, 780 F.2d 838, 842 (10th Cir. 1985). The Travel Act may be particularly useful in voter bribery cases in non-federal elections that involve the mailing of absentee ballot materials. Such matters usually involve a defendant who offers voters compensation for voting, followed by the voter applying for, obtaining, and ultimately casting an absentee ballot. Each voting transaction can involve as many as four separate mailings: (1) when the absentee ballot application is sent to the voter, (2) when the completed application is sent to the local election board, (3) when the absentee ballot is sent to the voter, and (4) when the voter sends the completed ballot back to the election authority for tabulation. Because the mailing must be in furtherance of the scheme, however, care should be taken to ensure that the voting transaction in question was corrupted by a bribe before the mailing that is 66