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10 11 12 13 14 15 16 17 18 19 20 21 Ze 23 24 Case 1:20-cr-00330-PAE Document565- Filed 12/19/21 Page16 of 83 CHARGE Instruction No. 10: Summary of Indictment The Indictment contains six counts, or “charges,” against the Defendant. Each count constitutes a separate offense or crime. You must consider each count of the Indictment separately, and you must return a separate verdict on each count. I am briefly going to summarize each count, and then will give you the law in greater detail. Count One of the Indictment charges Ghislaine Maxwell, the Defendant, with conspiring—that is, agreeing—with others to entice an individual to travel in interstate commerce to engage in sexual activity for which a person can be charged with a criminal offense. Count One relates to multiple alleged victims and the time period 1994 to 2004. Count Two of the Indictment charges the Defendant with enticing an individual to travel in interstate commerce to engage in sexual activity for which a person can be charged with a criminal offense. Count Two relates solely to Jane and the time period 1994 to 1997. Count Three of the Indictment charges the Defendant with conspiring with others to transport an individual under the age of seventeen in interstate commerce, with intent that the individual engage in sexual activity for which a person can be charged with a criminal offense. Count Three relates to multiple alleged victims and the time period 1994 to 2004. Count Four of the Indictment charges the Defendant with transporting an individual under the age of seventeen in interstate commerce, with the intent that the individual engage in sexual activity for which a person can be charged with a criminal offense. Count Four relates solely to Jane and the time period 1994 to 1997. Count Five of the Indictment charges the Defendant with conspiring to engage in sex trafficking of individuals under the age of eighteen. Count Five relates to multiple alleged victims and the time period 2001 to 2004. 15 DOJ-OGR-00008722