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Case 22-1426, Document 79, 06/29/2023, 3536060, Page59 of 93 46 “induce[]” a child to engage in illegal sexual activity by transporting the minor across state lines with in- tent that the child engage in an illegal sex act, 18 U.S.C. § 3509(a)(8), and Count Three, as a conspiracy to commit Count Four, is an “offense involving [such] sexual ... abuse,” id. § 3283. See United States v. Sensi, No. 08 Cr. 253 (WWE), 2010 WL 2351484, at *2- 3 (D. Conn. June 7, 2010) (collecting cases interpreting the term “sexual abuse” to encompass “all crimes that would logically relate to the common understanding of sexual abuse even when found in chapters 110 (Sexual Exploitation and Other Abuse of Children’) and 117 (‘Transportation of Illegal Sexual Activity and Related Crimes’) of title 18”); Schneider, 801 F.3d at 196-97 (holding that Section 3283 applied to defendant con- victed of traveling with the purpose of engaging in sex with a minor victim, in violation of 18 U.S.C. § 2423(b)). Accordingly, even considering only the elements of the offenses, Counts Three and Four fall squarely within Section 3283's definition of an offense involving sexual abuse of a child. b. Maxwell’s Argument for Use of a Categorical Approach Lacks Merit Because Counts Three and Four qualify as “of- fense[s] involving the sexual ... abuse ... of a child,” 18 U.S.C. § 3283, even without resort to the facts of the case, the Court need not address Maxwell’s claim that the categorical approach applies in this context. But the arguments Maxwell advances in support of her claim are meritless in any event. DOJ-OGR-00021706