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616 KB

Extraction Summary

3
People
2
Organizations
1
Locations
1
Events
1
Relationships
3
Quotes

Document Information

Type: Legal filing (jury instructions)
File Size: 616 KB
Summary

This document contains Jury Instruction No. 20 from the trial of Ghislaine Maxwell, filed on December 18, 2021. It defines the first element of Count Four: Transportation of an Individual Under the Age of 17 to Engage in Illegal Sexual Activity. The text outlines that the Government must prove Maxwell knowingly transported 'Jane' in interstate commerce, noting that personal transportation is not required if she made arrangements (like purchasing tickets), and that the victim's consent is irrelevant to the charge.

People (3)

Name Role Context
Ms. Maxwell Defendant
Subject of the jury instruction regarding Count Four; accused of knowingly transporting Jane in interstate commerce.
Jane Victim/Individual
The individual under the age of 17 allegedly transported by Maxwell.
The Government Prosecution
The entity required to prove the elements of the crime beyond a reasonable doubt.

Organizations (2)

Name Type Context
The Government
Federal prosecutors
DOJ
Department of Justice (indicated by Bates stamp DOJ-OGR)

Timeline (1 events)

N/A
Transportation of an Individual Under the Age of 17 to Engage in Illegal Sexual Activity
Interstate commerce

Locations (1)

Location Context
Mentioned in struck-through text regarding foreign commerce.

Relationships (1)

Ms. Maxwell Alleged Perpetrator/Victim Jane
Instruction states Maxwell knowingly transported Jane for illegal sexual activity.

Key Quotes (3)

"The Government does not have to prove that Ms. Maxwell personally transported Jane across a state line."
Source
DOJ-OGR-00008568.jpg
Quote #1
"It is sufficient to satisfy this element that Ms. Maxwell was actively engaged, either personally or through an agent, in the making of the travel arrangements"
Source
DOJ-OGR-00008568.jpg
Quote #2
"the Defendant is guilty of this charge whether or not the individual agreed or consented to cross state lines."
Source
DOJ-OGR-00008568.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,726 characters)

Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 30 of 167
1 Instruction No. 20: Count Four: Transportation of an Individual Under the Age of 17
2 Minor to Engage in Illegal Sexual Activity – First Element
3
4 The first element of Count Four which the Government must prove beyond a reasonable
5 doubt is that Ms. Maxwell knowingly transported Jane in interstate or foreign commerce, as
6 alleged in the Indictment. The phrase, “transport an individual in interstate or foreign commerce”
7 means to move or carry, or cause someone to be moved or carried, from one state to another or
8 between the United States and a foreign country.
9 The Government does not have to prove that Ms. Maxwell personally transported Jane
10 across a state line. It is sufficient to satisfy this element that Ms. Maxwell was actively engaged,
11 either personally or through an agent, in the making of the travel arrangements, such as by
12 purchasing tickets necessary for Jane to travel as planned.
13 Ms. Maxwell must have knowingly transported, or caused the transportation of, Jane in
14 interstate commerce. This means that the Government must prove that Ms. Maxwell knew both
15 that she was causing Jane to be transported, and that Jane was being transported in interstate
16 commerce. As I have explained, an act is done knowingly when it is done voluntarily and
17 intentionally and not because of accident, mistake or some innocent reason.
18 It is the Defendant’s intent that matters here. If the Government establishes each of the
19 elements of this crime beyond a reasonable doubt, then the Defendant is guilty of this charge
20 whether or not the individual agreed or consented to cross state lines.
29
DOJ-OGR-00008568

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