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20 21 22 23 24 25 Case 22-1426, Document 58,_02/28/2023, 3475901, Paged of 221 A-205 3037 LCKVMAX8 Charge accident, mistake, or some innocent reason. It is the defendant's intent that matters here. If the government establishes each of the elements of the crime beyond a reasonable doubt, then the defendant is guilty of this charge whether or not the individual cross state lines. Instruction No. 21 individual under the age of activity. Second element. The second lement of must prove beyond a reasonable knowingly intent that Jane engage in sexual activity can be charged with a criminal o Count Four. Count doubt agreed or consented to Transportation of an 17 to engage in illegal sexual Four which the government is that Ms. Maxwell transported Jane in interstate commerce with the for which any person Fense in violation of New York law. Like Count Two, which an individual York Penal Law, Section 130.55, degree. Count Four alleges sexual I've already instructed you regarding that crime, activity for could be charged with a violation of New sexual abuse in the third and those instructions apply equally here. In order to establish for the government to prove tha was Ms. Maxwell's sole purpose state lines. A person may have motives for such conduct, this element, it's not necessary t the illegal sexual activity for transporting Jane across several different purposes or and each may prompt in varying degree SOUTHERN D STRICT REPORT ERS, P.C. (212) 805-0300 DOJ-OGR- 00020831