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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case 1:20-cr-00330-PAE Document565- Filed 12/19/21 Page 45 of 83 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 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 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 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 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 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 with the intent to engage in sexual activity for which any person can be charged with a criminal offense objective would be proved. Finally, Count Five charges Ms. Maxwell with participating in a conspiracy, from at least in or about 2001, up to and including in or about 2004, to commit sex trafficking of 44 DOJ-OGR-00008751