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Case 1:20-cr-00330-PAE Document621 Filed 02/25/22 Page9of51 how Maxwell and Epstein enticed her to . . . go across state lines to New York to be abused.” (Tr. 2889 (emphasis added)). On that Count, the Government reminded the jury that “Jane told you about traveling with Maxwell to New York,” and argued that “Jane didn’t end up in New York by accident.” (Tr. 2889-90 (emphasis added)). The Government also argued that the pattern of Jane’s relationship with the defendant and Epstein showed that the defendant “enticed Jane to New York.” (Tr. 2890 (emphasis added)). And the Government argued that the evidence showed the defendant “absolutely intended that Jane would be abused in New York.” (Ud. (emphasis added)). The Government explained that Count Four differed from Count Two in that it involved travel, and not enticement to travel. So, the Government argued, the evidence showed that “Jane was transported to New York,” and that the defendant was involved in making travel arrangements. (Tr. 2891 (emphasis added)). The Government also made clear that, in order to show a violation of New York law, the Government did not have to show “that abuse in New York actually happened,” so long as the defendant had the requisite intent. (Tr. 2892 (emphasis added)). Accordingly, “[t]he crime happened the moment [the defendant, Epstein, and Jane] crossed state lines,” and “to be very clear, when Epstein flew Jane to New York and Maxwell aided and abetted him, that’s enough too.” (Ud. (emphasis added)). For the conspiracy counts, the Government referenced its earlier discussion of the elements of the substantive Mann Act offenses. And the Government argued that, “even though Carolyn and Annie were not sexually abused in New York . . . that is what [the defendant and Epstein] both intended.” (Tr. 2895 (emphasis added); see Tr. 2895-96 (arguing that the defendant “groomed Annie for abuse after she had already visited Epstein in New York.” (emphasis added))). DOJ-OGR-00009571