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fe N Ww ws Oo OY ~] oO WO a oO a fe N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LCKVMAX8 When taken all acts and conduct existed as conclusively as would of an express agreement Document 767 Charge may warrant th In short, as far as the together and considered as whole, Filed 08/10/22 infer direct proof, first element of lake: Page 215 of 257 however, 3049 these that a conspiracy such as evidence the conspiracy is concerned, the government must prove beyond a reasonable doubt that at least two alleged conspira a mutual understanding, the law in the manner charged in Counts One, the indictment. Conspiracy to violate Instruction No. the conspiracy. Count One charges Ms. conspiracy in or about 2004, travel to engage in sexual charged with a criminal from at least to entice either spoken or unspoken, Three, tors came to to violate and Five of 34. Counts One, Three, and Five. federal law. First element. Object of Maxwell with participating ina charged in Count under the age of wh in connection with Count One of offense. The object of 17 to travel to engage in sexual ich any person could be charged with a criminal I have already reviewed th the indictment is to entice in or about 1994, up to and including individuals under the age of 17 to activity for which any person can be F the conspiracy individuals Two. F you doubt that the defendant agreed with a that those elements be done, then th nticement of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 activity for offense. lements of that offense find beyond a reasonable t least one other person individuals DOJ-OGR-00017236