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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 31 of 93 Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — Second Element — Illegal Sexual Activity Count Four alleges that the defendantMs. Maxwell knowingly transported the- indsadual|Jane Doe-1 pseudonym] in interstate commerce with the intent that the indsadualshe engage in sexual activity with Jeffrey Epstein for which any person can be charged with a criminal offense in violation of New York law. Like Count Two, Count Four alleges sexual activity for which an individual could be charged with a-crime under the criminal (or penab law ef New ¥eork Statea violation of New York Penal Law, Section 130.55, spectticalh-Sexual Abuse in the Third Degree. I have already instructed you regarding that crime, and those instructions apply equally here. Adapted from Sand et al., Modern Federal Jury Instructions, Instr. 64-18; New York State Penal Law §§ 15.20(3), 130.00, 130.05, 130.55; New York State Pattern Jury Instructions § 130.55; the charge of the Hon. Denise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC). 31 DOJ-OGR-00006097