DOJ-OGR-00011310.jpg

Case 1:20-cr-00330-PAE Document 714 Filed 07/12/22 Page/7of7 law, avoids incorrectly suggesting that the entirety of the witness’s testimony will describe events that took place after the witness reached the age of consent, and avoids prejudice to the Government from an unbalanced instruction. In the Government’s view, however, any concern that jurors will mistakenly think they should convict on the basis of some violation of another state’s laws is best addressed in the concluding jury instructions. Such instructions will make the most sense to the jurors once they have heard all the facts and been instructed regarding the elements of each offense charged in the Indictment. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: ___s/ Maurene Comey Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Southern District of New York Cc: Defense Counsel (by e-mail) DOJ-OGR-00011310