EFTA00074500

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
S2 20 Cr. 330 (MN) 
GHISLAINE MAXWELL, 
Defendant. 
[PROPOSED] JOINT REQUESTS TO CHARGE 
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TABLE OF CONTENTS 
INTRODUCTORY INSTRUCTIONS 
1 
Role of the Court 
1 
Role of the Jury 
2 
Sympathy: Oath As Jurors 
3 
Contact with Others/Social Media 
4 
Statements of Counsel and Court Not Evidence; Jury's Recollection Controls 
5 
Improper Considerations 
7 
All Parties Are Equal Before the Law 
8 
Presumption of Innocence and Burden of Proof 
9 
Reasonable Doubt 
10 
The Indictment 
12 
CHARGE 
13 
Summary of Indictment 
13 
Multiple Counts 
15 
Count Two: Enticement to Engage in an Illegal Sexual Activity — The Statute 
16 
Count Two: Enticement to Engage in Illegal Sexual Activity— The Elements 
17 
Count Two: Enticement to Engage in Illegal Sexual Activity — First Element 
18 
Count Two: Enticement to Engage in Illegal Sexual Activity — Second Element 
19 
Count Two: Enticement to Engage in Illegal Sexual Activity — Third Element 
20 
Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — The Statute  22 
Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — The Elements 23 
Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — First Element  24 
Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — First Element —
Consent Irrelevant 
25 
Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — Second Element 
 
26 
Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — Second Element 
— Illegal Sexual Activity 
27 
Count Four: Transportation of a Minor to Engage in Illegal Sexual Activity — Third Element —
Sexual Abuse in the Third Degree 
28 
Counts Two and Four: Failure to Accomplish Intended Activity is Immaterial 
29 
Count Six: Sex Trafficking of a Minor — Statute 
30 
Count Six: Sex Trafficking of a Minor — Elements 
31 
Count Six: Sex Trafficking of a Minor — First Element 
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Count Six: Sex Trafficking of a Minor — Second Element 
33 
Count Six: Sex Trafficking of a Minor — Third Element 
34 
Count Six: Sex Trafficking of a Minor — Fourth Element 
35 
Counts Two, Four, and Six: Aiding and Abetting 
37 
Counts One and Three and Five: Conspiracy to Violate Federal Laws— The Statute 
40 
Counts One and Three and Five: Conspiracy to Violate Federal Laws— Conspiracy and 
Substantive Counts 
41 
Counts One, Three and Five: Conspiracy to Violate Federal Law — The Elements 
43 
Counts One, Three, and Five: Conspiracy to Violate Federal Law — First Element 
44 
Counts One, Three, and Five: Conspiracy to Violate Federal Law — First Element: Object of 
the Conspiracy 
48 
Counts One, Three, and Five: Conspiracy to Violate Federal Law — Second Element: 
Membership in the Conspiracy 
50 
Counts One, Three, and Five Two: Conspiracy to Violate Federal Law — Third Element 
53 
Statute of Limitations 
55 
OTHER INSTRUCTIONS 
56 
Direct and Circumstantial Evidence 
56 
Inferences 
58 
Credibility of Witnesses 
60 
Credibility of Witnesses — Impeachment by Prior Inconsistent Statement 
62 
Conscious Avoidance 
63 
Venue 
65 
Time of Offense 
67 
Law Enforcement and Government Employee Witnesses 
68 
Formal / Informal Immunity of Government Witnesses 
69 
Expert Testimony 
70 
Limiting Instruction — Similar Act Evidence 
71 
Defendant's Testimony 
72 
Defendant's Right Not to Testify 
73 
Uncalled Witnesses — Equally Available to Both Sides 
74 
Particular Investigative Techniques Not Required 
75 
Use of Evidence from Searches 
76 
Use of Electronic Communications 
77 
Persons Not on Trial 
78 
Preparation of Witnesses 
79 
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Redaction Of Evidentiary Items 
80 
Charts and Summaries — Admitted as Evidence 
81 
Stipulations 
82 
Punishment Not to be Considered by the Jury 
83 
Right to Hear Testimony; Election of Foreperson; Communications with the Court; Juror 
Note-Taking 
84 
CONCLUDING REMARKS 
85 
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INTRODUCTORY INSTRUCTIONS 
Role of the Court 
You have now heard all of the evidence in the case, as well as the final arguments of the 
lawyers for the parties. My duty at this point is to instruct you as to the law. It is your duty to 
accept these instructions of law and apply them to the facts as you determine them. 
On these legal matters, you must take the law as I give it to you. Regardless of any 
opinion that you may have as to what the law may be—or ought to be—it would violate your 
sworn duty to base a verdict upon any other view of the law than that which I give you. If an 
attorney or anyone else at trial has stated a legal principle different from any that I state to you in 
my instructions, it is my instructions that you must follow. 
You should not single out any instruction alone stating the law, but you should consider 
my instructions as a whole when you retire to deliberate in the jury room. You may take a copy 
of these instructions with you into the jury room. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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Role of the Jury 
Your role is to pass upon and decide the fact issues that are in the case. You, the 
members of the jury, are the sole and exclusive judges of the facts. You pass upon the weight of 
the evidence or lack of evidence; you determine the credibility of the witnesses; you resolve such 
conflicts as there may be in the testimony; and you draw whatever reasonable inferences you 
decide to draw solely based on the evidence and from the facts as you have determined them. 
The evidence before you consists of the answers given by witnesses and the exhibits and 
stipulations that were received into evidence. If I have sustained an objection to a question or 
told you to disregard testimony, the answers given by a witness are no longer part of the 
evidence and may not be considered by you. In determining the facts, you must rely upon your 
own recollection of the evidence. I will instruct you at the end of these charges about your 
ability to request to have testimony read back and your access to other evidence admitted during 
the trial. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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Sympathy: Oath As Jurors 
Under your oath as jurors you are not to be swayed by sympathy or prejudice. You are to 
determine the guilt or innocence of the defendant solely on the basis of the evidence and subject 
to the law as I have charged you. 
Adapted from Sand, et al., Modern Federal -flay Instructions, Instr. 
2-12; and the charge of the Hon. Denise L. Cote in United States v. 
Purcell, 18 Cr. 081 (DLC). 
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Contact with Others/Social Media 
During your deliberations, you must not communicate with or provide any information to 
anyone by any means about this case. You may not use any electronic devices or media, such as 
a telephone, cell phone, smart phone, iPhone, Blackberry or computer; the Internet, or any 
intemet service, or any text or instant messaging service; or any internet chat room, blog, or 
website, such as Facebook, Instagram, LinkedIn, YouTube, Twitter, or Snapchat, to 
communicate to anyone any information about this case or to conduct any research about this 
case until I accept your verdict. In other words, you cannot talk to anyone on the phone or in 
person, correspond with anyone, or electronically communicate with anyone about this case. You 
can only discuss the case in the jury room with your fellow jurors during deliberations. 
Along the same lines, you should not try to access any information about the case or do 
research on any issue that arose during the trial from any outside source, including dictionaries, 
reference books, or anything on the Internet. In our judicial system, it is important that you are 
not influenced by anything or anyone outside of this courtroom. Your sworn duty is to decide 
this case solely and wholly on the evidence that was presented to you in this courtroom. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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Statements of Counsel and Court Not Evidence; 
Jury's Recollection Controls 
You must determine the facts by relying upon your own recollection of the evidence. 
This case is not to be decided on the rhetoric of either the attorneys for the Government or the 
attorneys for the Defendants. The lawyers' arguments are intended to convince you to draw 
certain conclusions from the evidence or lack of evidence. Those arguments are important. You 
should weigh and evaluate them carefully. But you must not confuse them with the evidence. If 
your recollection of the evidence differs from the statements of the lawyers, follow your 
recollection. 
You should draw no inference or conclusion for or against any party by reason of lawyers 
making objections or my rulings on such objections. Counsel have not only the right but the duty 
to make legal objections that they think are appropriate. You should not be swayed against the 
Government or the Defendant simply because counsel for either side has chosen to make an 
objection. Similarly, statements made by counsel when arguing the admissibility of evidence are 
not to be considered as evidence. 
If I comment on the evidence during my instructions, do not accept my statements in 
place of your recollection. Again, it is your recollection that governs. 
Do not concern yourself with what was said at side bar conferences or during my 
discussions with counsel. Those discussions related to rulings of law, which are my duty, and not 
to matters of fact, which are your duty to determine. 
At times I may have admonished a witness or directed a witness to be responsive to 
questions, to keep his or her voice up, or to repeat an answer. My instructions were intended only 
to clarify the presentation of evidence. You should draw no inference or conclusion of any kind, 
favorable or unfavorable, with respect to any witness or party in the case, by reason of any 
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comment, question, or instruction of mine. Nor should you infer that I have any views as to the 
credibility of any witness, as to the weight of the evidence, or as to how you should decide any 
issue that is before you. That is entirely your role. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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Improper Considerations 
Your verdict must be based solely upon the evidence or the lack of evidence. It would be 
improper for you to consider any personal feelings you may have about the defendant's race, 
ethnicity, religion, national origin, sex, age, or any other such factor. Similarly, it would be 
improper for you to consider any personal feelings you may have about the race, ethnicity, 
religion, national origin, sex, age, or any other similar factor of any other witness or anyone else 
involved in this case. It also would be improper for you to allow any feelings you might have 
about the nature of the crimes charged to interfere with your decision-making process. 
I remind you that before each of you was accepted and sworn to act as a juror, you were 
asked questions concerning competency, qualifications, fairness, and freedom from prejudice 
and bias. On the faith of those answers, you were accepted as jurors by the parties. Therefore, 
those answers are as binding on each of you now as they were then, and should remain so, until 
the jury is discharged from consideration of this case. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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All Parties Are Equal Before the Law 
You are to perform the duty of finding the facts without bias or prejudice as to any party. 
You are to perform your final duty in an attitude of complete fairness and impartiality. 
The fact that the prosecution is brought in the name of the United States of America 
entitles the Government to no greater consideration than that given to any other party to this 
litigation. By the same token, the Government is entitled to no less consideration. All parties 
stand as equals at the bar of justice. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Lebedev, 
15 Cr. 769 (AN). 
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Presumption of Innocence and Burden of Proof 
The law presumes the defendant to be innocent of all charges against her. She has 
pleaded not guilty to the charges in the Indictment. As a result, the burden is on the Government 
to prove the defendant's guilt beyond a reasonable doubt as to each charge. This burden never 
shifts to the defendant. In other words, she does not have to prove her innocence. 
This presumption of innocence was with the defendant when the trial began remains with 
the defendant unless and until you are convinced that the Government has proven the defendant's 
guilt beyond a reasonable doubt. If the Government fails to prove the defendant's guilt beyond a 
reasonable doubt, you must find her not guilty. 
[If necessaty: Even though the defendant has presented evidence in her defense, the 
presumption of innocence remains with her. It is always the Government's burden to prove each 
of the elements of the crimes charged beyond a reasonable doubt.] 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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Reasonable Doubt 
The question that naturally arises is: "What is a reasonable doubt?" What does that 
phrase mean? The words almost define themselves. A reasonable doubt is a doubt based in 
reason and arising out of the evidence in the case, or the lack of evidence. It is a doubt that a 
reasonable person has after carefully weighing all of the evidence in the case. 
Reasonable doubt is a doubt that appeals to your reason, your judgment, your experience, 
and your common sense. If, after a fair and impartial consideration of all the evidence, you can 
candidly and honestly say that you do have an abiding belief of the defendant's guilt as to any 
crime charged in this case, such a belief as a prudent person would be willing to act upon in 
important matters in the personal affairs of his or her own life, then you have no reasonable 
doubt, and under such circumstances it is your duty to convict the defendant of the particular 
crime in question. 
On the other hand, if after a fair and impartial consideration of all the evidence, you can 
candidly and honestly say that you are not satisfied with the defendant's guilt as to any charge, 
that you do not have an abiding belief of her guilt as to that charge—in other words, if you have 
such a doubt as would reasonably cause a prudent person to hesitate in acting in matters of 
importance in his or her own affairs—then you have a reasonable doubt, and in that 
circumstances it is your duty to acquit the defendant of that charge. 
One final word on this subject: Reasonable doubt is not whim or speculation. It is not an 
excuse to avoid an unpleasant duty. Nor is it sympathy for the defendant. "Beyond a reasonable 
doubt" does not mean mathematical certainty, or proof beyond all possible doubt. The law in a 
criminal case is that it is sufficient if the guilt of the defendant is established beyond a reasonable 
doubt, not beyond all possible doubt, and, therefore, if after a fair and impartial consideration of 
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all of the evidence, you are satisfied beyond a reasonable doubt of the defendant's guilt with 
respect to a particular charge against her, you should find the defendant guilty of that charge. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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The Indictment 
The defendant, GHISLAINE MAXWELL, has been formally charged in what is called an 
Indictment. An indictment is simply a charge or accusation. It is not evidence. It is not proof of 
the defendant's guilt. It creates no presumption and it permits no inference that the defendant is 
guilty. You are to give no weight to the fact that an indictment has been returned against the 
defendant. 
I will not read the entire Indictment to you at this time. Rather, I will first summarize the 
offenses charged in the Indictment and then explain in detail the elements of each of the offenses. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 
17 Cr. 151 (AJN). 
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CHARGE 
Summary of Indictment 
The Indictment contains six counts, or "charges," against the defendant. Each count 
constitutes a separate offense or crime. You must consider each count of the Indictment 
separately, and you must return a separate verdict on each count in which the defendant is 
charged. I am briefly going to summarize each count, and then will give you the law in greater 
detail. 
Count One of the Indictment charges GHISLAINE MAXWELL, the defendant, with 
conspiring—that is, agreeing—with others to entice an individual to travel in interstate and 
foreign commerce to engage in sexual activity for which a person can be charged with a criminal 
offense: Count One relates to multiple victims and the time period 1994 to 2004. 
Count Two of the Indictment charges the defendant with enticing an individual to travel 
in interstate and foreign commerce to engage in sexual activity for which a person can be 
charged with a criminal offense. Count Two relates to Minor Victim-1 and the time period 1994 
to 1997. 
Count Three of the Indictment charges the defendant with conspiring 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 Three relates to 
multiple minor victims and the time period 1994 to 2004. 
Count Four of the Indictment charges the defendant with transporting a minor in 
interstate and foreign commerce, with the intent that the minor engage in sexual activity for 
which a person can be charged with a criminal offense. Count Four relates to Minor Victim-1 
and the time period 1994 to 1997. 
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Count Five of the Indictment charges the defendant with conspiring to engage in sex 
trafficking of minors. Count Five relates to multiple minor victims and the time period 2001 to 
2004. 
Count Six of the Indictment charges the defendant with sex trafficking of minors. Count 
Six relates to Minor Victim-4, and the time period 2001 to 2004. 
Adapted from Sand et al., Modern Federal Jury Instructions, Instr. 
3-6. See United States v. Sanzo, 673 F.2d 64, 69 (2d Cir. 1982). 
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Multiple Counts 
As I mentioned, the Indictment contains six counts. Each count charges the defendant 
with a different crime. 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, unless you are instructed 
otherwise. 
With that summary of the Indictment as background, I will now give you detailed 
instructions that relate to the crimes charged in Counts One through Six. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Pizarro, 17 Cr. 151 (AJN) and in United States v. Le, 15 
Cr. 38 (AJN). 
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Count Two: Enticement to Engage in an Illegal Sexual Activity — The Statute 
The relevant statute for Count Two is Title 18, United States Code, Section 2422, which 
provides that "[w]hoever knowingly persuades, induces, entices, or coerces any individual to 
travel in interstate or foreign commerce, or in any Territory or Possession of the United States, to 
engage in ... in any sexual activity for which any person can be charged with a criminal 
offense," is guilty of a federal crime. 
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