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Case 1:20-cr-00330-AJN Document 144 Filed 02/04/21 Page 8 of 25 phrase “offense involving” particular conduct refers to an offense whose elements necessarily entail that conduct. Because none of the offenses with which Ms. Maxwell has been charged necessarily entails or requires the sexual or physical abuse or kidnapping of a child, § 3283 does not apply here. SUMMARY OF ALLEGATIONS Counts One through Four of the indictment allege that Ms. Maxwell violated and conspired to violate two separate provisions of the Mann Act, 18 U.S.C. §§ 2421-2424. These counts are based on conduct that occurred at unspecified times between 1994 and 1997. Count One of the indictment alleges that Ms. Maxwell violated 18 U.S.C. § 2422 (now § 2422(a))' by conspiring to entice “one or more individuals” to travel in interstate and foreign commerce to engage in “sexual activity for which a person can be charged with a criminal offense.” Indictment {fj 9-10. Count Two charges Ms. Maxwell with a substantive § 2422(a) violation, claiming she “persuaded, induced, enticed, and coerced” an individual identified as Minor Victim-1 to travel from Florida to New York “with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55.” Jd. ¥ 13. Count Three alleges that Ms. Maxwell conspired to transport “an individual” in interstate and foreign commerce to engage in “sexual activity for which a person can be charged with a criminal offense” in violation of 18 U.S.C. § 2423(a). Indictment §] 15-16. Count Four charges Ms. Maxwell with a substantive § 2423(a) violation, claiming she “arranged for Minor Victim-1 to be transported from Florida to New York, New York on multiple occasions with the intention ' Prior to February 8, 1996, the provision at issue constituted the entirety of § 2422; it became § 2422(a) as a result of the enactment of additional subsections as of that date. Telecommunications Act of 1996, PL 104-104, Feb. 8, 1996, Title V, § 508, 110 Stat. 56. Thus, the provision is referred to herein as § 2422(a). DOJ-OGR-00002656