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Case 22-1426, Document 57_02/28/2023, 3475900, Page207 of 208 A-203 3035 LCKVMAX8 Charge 1 that the intended acts were nonconsensual solely because of the 2 victim's age, you must find that Ms. Maxwell knew that Jane was 3 less than 17 years old. 4 Instruction No. 18. Count Four. Transportation of an 8 individual under the age of 17 to engage in illegal sexual 6 activity. The statute. 7 The relevant statute for Count Four is Title 18, 8 United States Code, Section 2423(a), which provides that a 9 person who "knowingly transports any individual under the age 10 of 17 years in interstate commerce, with the intent that such 1] individual engage in any sexual activity for which any person 12 can be charged with a criminal offense" is guilty of a federal 13 crime. 14 Instruction No. 19. Count Four. Transportation of an 15 individual under the age of 17 to engage in illegal sexual 16 activity. The elements. 17 In order to prove the defendant guilty of Count Four, 18 the government must establish each of the following three 19 elements of the crime beyond a reasonable doubt: 20 First, that the defendant knowingly transported an 2] individual in interstate commerce as alleged in the indictment. 22 Second, that the defendant transported the individual 23 with the intent that the individual would engage in sexual 24 activity for which any person can be charged with a criminal 25 offense under New York law as alleged in the indictment. SOUTHERN DISTRICT REPORTERS, (212) 805-0300 .C. DOJ-OGR-00020825