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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 759 _ Filed 08/10/22 Page 239 of 267 2267 LCAVMAX8 allegedly participated in this conspiracy persuaded, induced, or enticed Jane to travel to New York to engage in illegal sexual activity. Your Honor, these words "persuade, induce, entice," these are words of causation. And I am now quoting from U.S. v. Broxmeyer, 616 F.3d 120 (2d Cir. 2010), and that's at page 125. This is a decision that addresses 2251, not 2242, but that statute has the same words "persuade, induce, entice," and it's interpreting in the same way. And Broxmeyer says that these are words of causation, which means they have to bring about an effect. There has to be something done by the defendant to bring about an effect. And in discussing the dictionary definitions, these words are usually given their dictionary definitions, but they do discuss in this opinion what those typically are. And they quote from the Random House Dictionary. "Induce" means, according to the dictionary, to bring "Entice" means to draw on by about, produce, or cause. exciting hope or desire or allure. And "persuade" means to prevail on a person to do something as by advising, urging, etc., to induce to believe or convince. So, again, these are words of causation. Now, the only testimony that we have in the record that relates in any way to Ms. Maxwell taking part in Jane's travel to New York is that Jane testified as to the following SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013830