In State in the Interest of M.T.S., 129 N.J. 422, 609 A.2d 1266 (1992), the New Jersey Supreme Court reviewed the legislative history of N.J.S.A. 2C:14-1-7, the Sexual Offenses Statute. The Court noted that our Legislature did not adopt the Model Penal Code definitions of sexual assault when enacting the Code of Criminal Justice in 1979. The Court stated that "the Model Sex Offense Statute in turn had been based on selected provisions of the Michigan Criminal Sexual Conduct Statute, Mich. Stat. Ann. Section 28.788 (4)(b) (Callaghan 1990.), (M.C.L.A. Section 750.520d) and on reform statutes in New Mexico, Minnesota and Wisconsin. Although M.T.S. did not involve discussion of the term "upon the actor's instruction," it did relate in detail the departure of the Code of Criminal Justice from the Model Penal Code definitions of sexual misconduct. As the Court observed: Since the 1978 reform, the Code has referred to the crime that was once known as "rape" as "sexual assault." The crime now requires "penetration," not "sexual intercourse." It requires "force" or "coercion," not "submission" or "resistance." It makes no reference to the victim's state of mind or attitude, or conduct in response to the assault. It eliminates the spousal exception based on implied consent. It emphasizes the assaultive character of the offense by defining sexual penetration to encompass a wide range of sexual contacts, going well beyond traditional "carnal knowledge." Consistent with the assaultive character, as opposed to the traditional sexual character, of the offense, the statute also renders the crime gender-neutral: both males and females can be actors or victims. Id. at 440-441, 609 A.2d 1266. In footnote 2, following the Court's reference to "carnal knowledge", the Court said the following: (T)his reform replaced the concept of carnal abuse, which was limited to vaginal intercourse, with specific kinds of sexual acts contained in a broad definition of penetration: Sexual penetration means vaginal intercourse, cunnilingus, fellatio or anal intercourse between persons or insertion of the hand, finger or object into the anus or vagina either by the actor or upon the actor's instruction. (N.J.S.A. 2C:14-1) Id. at 440, FN 2, 609 A.2d 1266