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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 37 of 93 Count Six: Sex Trafficking of a Minor — Second Element The second element of Count Six which the government must prove beyond a reasonable doubt is that Ms. Maxwell the-defendant knew that [Jane Doe-4 pseudonym on-Was under eighteen years of age. In considering whether Ms. Maxwell the defendant knew that [Jane Doe-4 pseudonym the person-had not attained the age of eighteen, please apply the definition of “knowingly” previously provided to you. Adapted from Sand, et al., Modern Federal Jury Instructions, Instr. 47A-20; and the charge given by the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW). See United States v. Thompson, 896 F.3d 155, 169-70 (2d Cir. 2018). 37 DOJ-OGR-00006103