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be N Ww ws Oo OY ~] oO WO Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LCKVMAX8 deliberately and purposely and not because of accident. available; required. a person wrotl an act with a part Direct proof of Document 767 ings would be a rar te or stated that as of ticular intent. The ultimate fact of be established by circumstantial de acts, evidence and the rational drawn Signi was Ms. fendant's out and all Maxwe] tLward mani from them. across state lines. purposes or motives In order to establish for the government to prove tha ll's sole purpose A person may have several varying degr beyond a reasonable doubt, motivating purpose of lines was that other words, merely incidental to Violation o Count Two al the trip. for such conduct, the person's actions. however, fF encouraging Jane New York criminal Ficant or motivating purpose. this element, Filed 08/10/22 Page 199 of 257 3033 Charge mistake or a person's intent is almost never case where it could be shown that a given time, she committed Such direct proof is not intent, though subjective, may vidence based upon the Festations, her words, her conduct, her the surrounding circumstances disclosed by the or logical inferences that may be it's not necessary or encouraging Jane to di fferent that law. lleges that Ms. a signif and each may prompt The government must SOUTH ERN D STR CT RE PORTERS, (212) 805-0300 fFicant or she would engage in illegal sexual activity. the illegal sexual activity must not have been Maxwell enticed Jane to the illegal sexual activity travel in prove to travel across state DOJ-OGR-00014599