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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 767 _ Filed 08/10/22 Page 197 of 257 3031 LCKVMAX8 Charge government must prove each of the following three elements beyond a reasonable doubt: First, that the defendant knowingly persuaded or induced or enticed or coerced an individual to travel in interstate commerce as alleged in the indictment. Second, that the individual traveled in interstate commerce. And third, that the defendant acted with the intent that the individual would engage in sexual activity for which any person could be charged with a criminal offense under New York law as alleged in the indictment. Count Two relates solely to Jane during the time period 1994 to 1997. Instruction No. 15. Count Two, enticement to engage in illegal sexual activity. First element. The first element of Count Two which the government must prove beyond a reasonable doubt is that Ms. Maxwell knowingly persuaded or induced or enticed or coerced an individual to travel in interstate commerce as alleged in the indictment. The terms "persuaded, induced, enticed, and coerced" have their ordinary everyday meanings. The term "interstate commerce" simoly means movement from one state to another. The term "state" includes a state of the United States and the District of Columbia. "Knowingly" defined. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017218