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Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 62 of 257 2895 LCKCmax3 Summation - Ms. Moe 1 was abused on a massage table that was manufactured in 2 California, that proves that there was at least a minimal 3 effect on interstate commerce, which is all that's required for 4 this count. 5 Finally, there are thr conspiracy counts that charge 6 Maxwell with conspiring with Epstein to commit the three crimes 7 that we just talked about. I expect Judge Nathan will instruct 8 you that a conspiracy just means an agreement to break the law. 9 The crime is the agreement and taking some step to carry it 10 out. So the question for you here is, did Maxwell agree with 11 Epstein to commit these crimes. The conspiracy counts are 12 counts One, Three, and Five. 13 The first two conspiracy counts are from 1994 to 2004. 14 Those counts are about Jane, Carolyn, and Annie. Those counts 15 charge a conspiracy related to enticement and travel, as we've 16 just discussed. We've already talked about how Maxwell and 17 Epstein completed these crimes as to Jane. For the conspiracy 18 charges, even though Carolyn and Annie were not sexually abused 19 in New York, everything about the defendant's and Epstein's 20 interactions with those girls makes it clear that that is what 21 they both intended. Maxwell groomed both Annie and Carolyn as 22 part of a broader agreement with Epstein to provide him with 23 underage girls for abuse. You heard about all of the steps the 24 defendant took in those years in furtherance of that 25 conspiracy, how Maxwell traveled with Jane and groomed Annie SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017083