DOJ-OGR-00011543.jpg

be NO Ww ws Oo OY ~] oO Ke) a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 737 M6éSOmaxl that it certain still going to the house. was still going Filed 07/22/22 Page 24 of 101 24 ly was. The message pads show that Carolyn was Her testimony establishes that she to the house throughout that time period. We do not agree that we're required to show that any conspirator took a specific act in that exact window but just that the conspiracy was still live, and the additional acts throughout 2004 and into 2005 satisi ratifying membership of fac that there were the conspiracy fies that burden. THE COURT: Again, just to make sure I'm not missing anything you want to point to, the into 2005 is pointing to post conspiracy conduct. MS. MOE: THE COURT: Post indictment. post conspiracy MS. MOE: 2 El Well, your Honor, Post indictment conduct, your Honor. Is it in some way not again, the question before the Court, according to the application is when the did offense end. THE COURT: Ms. Moe, I do understand you're framing that question. I'm asking record vidence question. Is there something you're pointing to for your s which consists of conspiratorial conduct MS. MO would point to in the fall of 2004 Et think separate tLatement, the post 2005 t? from the 2005 evidence, w , a message from Carolyn in November of 2004 showing that she was contacting the house to make a scheduled appointment. SOUTHERN DISTRICT RE PORT (212) 805-0300 BRS, P«G.# DOJ-OGR-00011543