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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 35 of 93 Count Six: Sex Trafficking of a Minor — Elements To find the defendantMs. Maxwell guilty of Count Six the Government must prove each of the following four elements beyond a reasonable doubt: First: ThedefendantMs. Maxwell knowingly recruited, enticed, harbored, transported, provided, or obtained [Jane Doe-4 pseudonym ]apersen; Second: ThedefendantMs. Maxwell knew that [Jane Doe-4 pseudonym was under the age of eighteen years; Third: Fhe-defendantMs. Maxwell knew the-persenthat [Jane Doe-4 pseudonym] would be caused to engage in a commercial sex act; and Fourth: Thedefendant’sMs. Maxwell’s acts were in or affecting interstate or foreign commerce. This Count relates to the alleged abuse-of [Jane Doe-4_pseudonym]Miner Victim—4- during the time period 2001 to 2004. Adapted from Sand, et al., Modern Federal Jury Instructions, Instr. 47A-18; and the charge given by the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW). 35 DOJ-OGR-00006101