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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 LCAVMAX8 Counts One and Two, Document 759 counts. THE COURT: All right. Tha Mr. Rohrbach. MR. ROHRBACH: f Your Honor, motion as to Counts One and Two. Jane was not in New York by accident. In this point Mr. Everdell Filed 08/10/22 nk you. may take the podium, for Jane to travel to New York. that's required b verbs that are in The jury could readily conclude, that all of Jane's CW n nticement, the enticement sta as travel to New Yor relationship that the defendant and That meets each of Jane's testimony is hopes and dreams to make her f is de "Enticement" de get her into this relationship over a mult oD Epstein built with Jane. inducement, tute and the government k was in Page 243 of 267 2271 the enticement conspiracy and substantive your Honor. the Court should deny the defendant's fact, there's no nonsexualized purpose that's been articulated at takes a very narrow view on the nexus and the other the travel itsel has argued, the context of the the verbs in the that the det statute. 1 sp which she was traveling with the det Similarly, persuasion, sorry, SOUTHERN D Jane testified that the det cial, Fined as using hope and desire. fendant was playing on Jane's hopes and desires seen, Fendant played on her and cared for. So the in order to ti-year period in Fendant. the defendan fFendant developed a t testified that -- friendship STR CT RE PORTERS, (212) 805-0 300 PG ew DOJ-OGR-00013834