DOJ-OGR-00021727.pdf

--- Page 1 --- **Case 22-1426, Document 79, 06/29/2023, 3536060, Page80 of 93** **Header:** Case 22-1426, Document 79, 06/29/2023, 3536060, Page80 of 93 **Footer:** DOJ-OGR-00021727 **Page Number:** 67 **Document Text:** and specific sexual acts that took place in New York while Jane was a minor (Tr.319-20). The Government's summation similarly discussed these charges as encompassing conduct directed at New York. As to Count Four, the Government argued the evidence showed "Jane was transported to New York," and Maxwell was involved in making travel arrangements. (Tr.2891 (emphasis added)). The Government also clarified that "[t]he crime happened the moment [Maxwell, 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." (Id. (emphasis added)). For the conspiracy counts, the Government referenced its earlier discussion of the elements of the substantive offenses. And the Government argued that, "even though Carolyn and Annie were not sexually abused in New York ... that is what [Maxwell and Epstein] both intended." (Tr.2895 (emphasis added); see Tr.2895-96 (arguing that Maxwell "groomed Annie for abuse after she had already visited Epstein in New York." (emphasis added))). The District Court's jury instructions also permitted the jury to determine only whether Maxwell had intended that Jane (for the substantive counts) or the conspiracy victims engage in sexual activity in New York. During trial, Judge Nathan granted defense requests for limiting instructions at the time evidence came in to make clear that the charges focused on the intent that sexual activity take place in New York. (Tr.1167-68 (Kate), 2048-49 (Annie)). At the conclusion of trial, Judge Nathan instructed the jury that Count.