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Case 1:20-cr-00330-PAE Document 759 _~— Filed 08/10/22 Page 246 of 267 2274 LCAVMAX8 1 And if it's going to be on an aiding and abetting 2 theory, then she has to have aided Jeffrey Epstein or some 3 other person to have done the same thing. And I don't see any 4 vidence in the record about Jeffrey Epstein enticing her to 5) travel to New York. All we heard of was travel to New York. 6 And there could be any number of reasons why she traveled to 7 New York. But there is no hard evidence that there was 8 enticement to travel, convincing her to travel for that 9 purpose. So I don't think either on an aiding and abetting 10 theory, it also doesn't work. 11 The only other point I would make, your Honor, is that 12 [ want to be clear on the record that we are making this 13 application as to all counts, although my comments are reserved 14 for the first two counts. 15 THE COURT: Understood. All right. Thank you. 16 The motions are denied. 17 What do we need to discuss before Thursday? 18 MS. MOE: Your Honor, we just wanted to confirm on the 19 record that we would be receiving defense exhibits and Rule 26 20 material today. 21 THE COURT: Counsel? 22 MR. PAGLIUCA: We should have those materials today, 23 your Honor. There's a little bit of fluidity in terms of the 24 witnesses, and perhaps even if there are Rule 26 materials, 25 frankly, which I don't suspect that there are. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ- OGR-00013837