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10 11 12 13 14 15 16 17 18 19 20 21 22 23 Case 1:20-cr-00330-PAE Document563_ Filed 12/18/21 Page 40 of 167 Instruction No. 30: 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 to Counts Two, Four, and Six, therefore, the Defendant can be convicted either if she committed the crime herself, or if another person committed the crime and the Defendant aided and abetted that person to commit that crime. Under the federal aiding and abetting statute, whoever “aids, abets, counsels, commands, induces, or procures” the commission of an offense is punishable as a principal. You should give those words their ordinary meaning. A person aids or abets a crime if she knowingly does some 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 to bring something about, to effect something. In other words, it is not necessary for the Government to show that Ms. Maxwell herself physically committed the crime charged in order for you to find her guilty. This is because a person who aids, abets, counsels, commands, induces, or procures the commission of a crime is just as guilty of that offense as if she committed it herself. Accordingly, you may find Ms. Maxwell 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 39 DOJ-OGR-00008578