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be NO Ww ws Oo OY ~] oO Ke) a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 767 LCKVMAX8 Charge accident, mistake, or some innocent reason. the government establishes each of beyond a reasonable doubt, then the def charge whether or not the individual It is the defendant's in Filed 08/10/22 Page 203 of 257 3037 tent that matters here. If the elements of the crime cross state lines. Instruction No. 21. Count Four. ndant is guilty of this agreed or consented to Transportation of an individual under the age of 17 to engage in illegal sexual activity. Second element. The second element of Count Four which the government must prove beyond a reasonable doubt is that Ms. Maxwell knowingly transported Jane in interst intent that Jane engage in sexual can be charged with a criminal 3 oe Late commerce with the offense law. tivity for which any person in violation of New York Like Count Two, Count Four alleges sexual activity for which an individual could be charged with a violation of New York Penal Law, Section 130.55, sexual abuse in the third degree. I've already instructed you regarding that crime, and those instructions apply equally here. was Ms. Maxwell's sole purpose In order to establish state lines. A person may have several this element, it's not necessary for the government to prove that the illegal sexual activity for transporting Jane across di fferent purposes or motives for such conduct, and each may prompt in varying degree SOUTHERN DISTR CT RE PORT ERS, (212) 805-0300 PG ew DOJ-OGR-00017224