EFTA00018008.pdf

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pdf

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data-set-8

Original source

Extracted text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
GHISLAINE MAXWELL, 
Defendant. 
INSTRUCTIONS TO FOCUS GROUP 
EFTA00018008


Summary of Indictment 
The Indictment contains three counts. or "charges," against GHISLAINE MAXWELL, 
the defendant. 
Count One of the Indictment charges the defendant, with conspiring—that is, agreeing—
with others to transport a minor in interstate and foreign commerce, with intent that the minor 
engage in sexual activity for which a person can be charged with a criminal offense. Count One 
relates to multiple minor victims during the time period 1994 to 2004. 
Count Two of the Indictment charges the defendant with conspiring to engage in sex 
trafficking of minors. Count Two relates to multiple minor victims during the time period 2001 
to 2004. 
Count Three of the Indictment charges the defendant with sex trafficking of minors. 
Count Three relates to Minor Victim-4, during the time period 2001 to 2004. 
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Burden of Proof and Multiple Counts 
In a moment, I will describe those three counts in more detail. Before I do, however, let 
me explain that the Government has the burden of proving the defendant's guilt on each count by 
a preponderance of the evidence. That means that the Government must show that it is more 
likely than not that the defendant is guilty of each count. 
You must consider each count separately and return a separate verdict of guilty or not 
guilty for each. Whether you find the defendant guilty or not guilty as to one offense should not 
affect your verdict as to any other offense charged. 
You have no doubt heard that a defendant's guilt in a criminal case must be proved 
beyond a reasonable doubt. That is not the standard we are applying in today's exercise. As I 
said, the question for you today is whether it is more likely than not that the defendant is guilty 
of each count. 
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Count One: Conspiracy to Transport Minors 
As I mentioned, Count …

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