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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 10 of 37 instead instructed the jury that the government needed to prove travel “in interstate commerce, as alleged in the Indictment.” Dkt. 565 at 22. The government also objected to the defense’s request that the jury instructions for the Mann Act conspiracy counts specify the ages of consent in the relevant jurisdictions, stating the following: “The Government’s proposed instructions only permit the jury to convict on a violation of New York Penal Law Section 130.55. Accordingly, there is no reason to inform the jury about the ages of consent in other jurisdictions.” Dkt. 410-1 at 52 (emphasis added). The Court agreed with the government and did not include this instruction. Finally, the defense requested that the jury charge reiterate the Court’s limiting instructions for Kate and Annie Farmer in the section of the charge that addressed the violation of New York law. Tr. 2773:5-2774:14. The defense also requested a separate instruction in the same section to address Jane’s testimony that she was sexually abused at Epstein’s ranch in New Mexico when she was 15 or 16 — information that was disclosed for the first time just before trial. Tr. 2775:14-2777:6.' The defense pointed out that this conduct was not alleged in the Indictment and could not be a violation of New York law, and therefore the jury should be instructed, similar to Kate and Annie Farmer, that this evidence could not be considered “illegal sexual activity” as charged in the Indictment. Tr. 2775:24-2776:4. In responding to both requests, the government stressed that there was no risk that the jury would convict Ms. Maxwell on the Mann Act counts based solely on conduct that did not violate New York law, such as sexual activity in New Mexico. With regard to Annie Farmer’s testimony, the government stated: ! According to the FBI reports of her prior interviews, Jane initially denied that she was sexually abused in New Mexico. See 3509-008 at 7-11. Shortly before trial, after being questioned by the government on this topic, Jane recalled for the first time being led to Epstein’s room in New Mexico and being sexually abused. See 3509-033 at 1. She then reiterated this in her testimony. See Tr. 323:15-16 (“I just remember being led to his bedroom and, you know, the same thing would happen.”). DOJ-OGR- 00008934