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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 47 of 167 Instruction No. 34: Counts One, Three, and Five: Conspiracy to Violate Federal Law — First Element: Object of the Conspiracy Count One charges Ms. Maxwell with participating in a conspiracy from at least in or about 1994, up to and including in or about 2004, to entice individuals under the age of 17 miners-to travel to engage in sexual activity for which any person can be charged with a criminal offense. The object of the conspiracy charged in Count One of the Indictment is to entice individuals under the age of 17 miners-to travel to engage in sexual activity for which any person can be charged with a criminal offense. I have already reviewed the elements of that offense in connection with Count Two. If you find beyond a reasonable doubt that the Defendant agreed with at least one other person that those elements be done, then the enticement of individuals under the age of 17 miners-to travel to engage in sexual activity for which any person can be charged with a criminal offense objective would be proved. Count Three charges the Defendant with participating in a conspiracy, from at least in or about 1994, up to and including in or about 2004, to transport individuals under the age of 17 miners-with the intent to engage in sexual activity for which any person can be charged with a criminal offense. The object of the conspiracy charged in Count Three of the Indictment is to transport individuals under the age of 17 miners-with the intent to engage in sexual activity for which any person can be charged with a criminal offense. I have already reviewed the elements of that offense in connection with Count Four. If you find beyond a reasonable doubt that the Defendant agreed with at least one other person that those elements be done, then the transportation of individuals under the age of 17 mimners-with the intent to engage in sexual activity for which any person can be charged with a criminal offense objective would be proved. 46 DOJ-OGR-00008585