DOJ-OGR-00014601.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 767** **Charge** **Filed 08/10/22** **Page 201 of 257** **3035** **LCKVMAX8** that the intended acts were nonconsensual solely because of the victim's age, you must find that Ms. Maxwell knew that Jane was less than 17 years old. Instruction No. 18. Count Four. Transportation of an individual under the age of 17 to engage in illegal sexual activity. The statute. The relevant statute for Count Four is Title 18, United States Code, Section 2423(a), which provides that a person who "knowingly transports any individual under the age of 17 years in interstate commerce, with the intent that such individual engage in any sexual activity for which any person can be charged with a criminal offense" is guilty of a federal crime. Instruction No. 19. Count Four. Transportation of an individual under the age of 17 to engage in illegal sexual activity. The elements. In order to prove the defendant guilty of Count Four, the government must establish each of the following three elements of the crime beyond a reasonable doubt: First, that the defendant knowingly transported an individual in interstate commerce as alleged in the indictment. Second, that the defendant transported the individual with the intent that the individual would engage in sexual activity for which any person can be charged with a criminal offense under New York law as alleged in the indictment. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014601