DOJ-OGR-00014597.pdf

--- Page 1 --- **Document Header** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 767 * **Charge:** Filed 08/10/22 * **Page Number:** Page 197 of 257 **Case Details** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 767 * **Charge:** Filed 08/10/22 * **Page Number:** Page 197 of 257 **Text of the Document** 1. government must prove each of the following three elements 2. beyond a reasonable doubt: 3. First, that the defendant knowingly persuaded or 4. induced or enticed or coerced an individual to travel in 5. interstate commerce as alleged in the indictment. 6. Second, that the individual traveled in interstate 7. commerce. 8. And third, that the defendant acted with the intent 9. that the individual would engage in sexual activity for which 10. any person could be charged with a criminal offense under New 11. York law as alleged in the indictment. 12. Count Two relates solely to Jane during the time 13. period 1994 to 1997. 14. Instruction No. 15. Count Two, enticement to engage 15. in illegal sexual activity. First element. 16. The first element of Count Two which the government 17. must prove beyond a reasonable doubt is that Ms. Maxwell 18. knowingly persuaded or induced or enticed or coerced an 19. individual to travel in interstate commerce as alleged in the 20. indictment. The terms "persuaded, induced, enticed, and 21. coerced" have their ordinary everyday meanings. The term 22. "interstate commerce" simply means movement from one state to 23. another. The term "state" includes a state of the United 24. States and the District of Columbia. 25. "Knowingly" defined. **Footer** * **SOUTHERN DISTRICT REPORTERS, P.C.** * **(212) 805-0300** * **DOJ-OGR-00014597**