This document is page 116 of 167 from a court filing (Document 563) dated December 18, 2021, in the case against Ghislaine Maxwell. It contains Jury Instruction No. 26 regarding the first element of Count Six: Sex Trafficking of an Individual Under the Age of 18. The text explicitly names 'Carolyn' as the specific individual the Government must prove Maxwell knowingly recruited or trafficked.
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the jury instruction regarding Count Six accusations.
|
| Carolyn | Alleged Victim |
Named as the person Ms. Maxwell allegedly recruited, enticed, harbored, transported, provided, or obtained.
|
| Name | Type | Context |
|---|---|---|
| Government |
The entity that must prove the element beyond a reasonable doubt.
|
|
| DOJ |
Department of Justice, indicated by the Bates stamp prefix DOJ-OGR.
|
"The first element of Count Six which the Government must prove beyond a reasonable doubt is that Ms. Maxwell knowingly recruited, enticed, harbored, transported, provided, or obtained a person, Carolyn."Source
"Instruction No. 26: Count Six: Sex Trafficking of an Individual Under the Age of 18 – First Element"Source
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