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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 41 of 93 Counts Two, Four, and Six: Aiding and Abetting In connection with the crimes charged in Counts Two, Four, and Six, the defendant is also charged with aiding and abetting the commission of those crimes. Aiding and abetting liability is its own theory of criminal liability. In effect, it is a theory of liability that permits a defendant to be convicted of a specified crime if the defendant, while not herself committing the crime, assisted another person or persons in committing the crime As te-Counts Pre Fentand Commented [CE55]: This language is unnecessary and redundant Moreover, it is not included in the Court’s most 20 CR 84 (AJN); United States v. Pizarro, 17 Cr 151 (AJN) induces, or procures” the commission of an offense is punishable as a principal. You should give ree tae se aouhtgan os pation those words their ordinary meaning. EN person aids or abets a crime if she knowingly does some 16 Cr 553 (AJN) Itis clarifying for the jury before the Court gives a more fulsome description of accomplice ‘eae Under the federal aiding and abetting statute, whoever “aids, abets, counsels, commands, act for the purpose of aiding or encouraging the commission of that crime. with the intention of causing the crime charged to be committed. To “counsel” means to give advice or recommend. To “induce” means to lead or move by persuasion or influence as to some action or state of mind. To “procure” means to bring about by unscrupulous or indirect means. To “cause” means about. to effect something. something to bring Commented [CE57]: The additional language is consistent States v. Berry, 20 CR 84 (AJN); United States v. Pizarro, 17 In other words, it is not necessary for the Government to show that Ms. Maxwell +e Cr 151 (AJN) defeadantherself physically committed the crime charged in order for you to find her guilty. ee eC ae iets namie that : carry their ordinary meaning (e g the verbs in the Mann Act This is because a person who aids, abets, counsels, commands, induces, or procures the and sex trafficking counts). there is no reason to do so here commission of a crime is just as guilty of that offense as if she committed it herself. Accordingly, you may find Ms. Maxwell the defendant guilty of the offenses charged in Counts Two, Four, and Six if you find beyond a reasonable doubt that the Government has proven that another person actually committed the offense with which Ms. Maxwell she-defeadantis 41 DOJ-OGR-00006107