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10 11 12 13 14 15 Case 1:20-cr-00330-PAE Document565- Filed 12/19/21 Page 22 of 83 Instruction No. 15: Count Two: Enticement to Engage in Illegal Sexual Activity — First Element The first element of Count Two which the government must prove beyond a reasonable doubt is that Ms. Maxwell knowingly persuaded or induced or enticed or coerced an individual to travel in interstate commerce, as alleged in the Indictment. The terms “persuaded,” “induced,” “enticed,” and “coerced” have their ordinary, everyday meanings. The term “interstate commerce” simply means movement from one state to another. The term “State” includes a State of the United States and the District of Columbia. 6 ‘Knowingly” Defined Ms. Maxwell must have acted knowingly. An act is done knowingly when it is done voluntarily and intentionally and not because of accident, mistake, or some other innocent reason. Now, knowledge is a matter of inference from the proven facts. Science has not yet devised a manner of looking into a person’s mind and knowing what that person is thinking. Whether Ms. Maxwell acted knowingly may be proven by Ms. Maxwell’s conduct and by all of the facts and circumstances surrounding the case. 21 DOJ-OGR-00008728