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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 43 of 93 2. Did Ms. Maxwell the defendant knowingly and willfully associate herself with the criminal venture? 3. Did Ms. Maxwell the defendant seek by her actions to make the criminal venture succeed? If she did, then Ms. Maxwell the-defendantis an aider and abettor, and therefore guilty of the offense. If, on the other hand, your answer to any of these questions is “no,” then Ms. Maxwell the defendant is not an aider and abettor, and you must find her not guilty under that theory. Adapted from Sand et al., Modern Federal Jury Instructions, Instr. 11-2; 18 U.S.C. § 2; the charge given by the Hon. Alison J. Nathan in United States v. Jones, 16 Cr. 553 (AJN) and in United States v. Pizarro, 17 Cr. 151 (AJN); and the charge given by the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW). 43 DOJ-OGR-00006109