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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 LCT1MAX1 the conspiracy co here to generaliz going to be applied later to the conspiracy counts, right? But this is the substantive count, says first that t unt CS come Document 765 later, Filed 08/10/22 Page 21 of 95 2759 [ think there is an attempt e the wording of the elements because it's he dei Fendant and if we look at the line 5, it knowingly persuaded or induced or enticed or coerced an individual to travel in interstate commerce. The individual in the substantive count is Jane. The defense request is for it to say not "an individual," replace that with "Jane to travel in interstate commerce from Florida to New York, as alleged in the indictment." THE COURT: Mr. Rohrbach. MR. ROHRBACH: So, your Honor, I don't think the jury will be confused. Both in the summary and later on in this section, it says this relates to Jane. like it to say it relates solely summary, that wou ld be the elements of t elements. Mr. Everdell can correct me, proposed requests to charge is whether he offense and fine, but the factual predicates of I think here and Jane, travel to New York, be included in th defense is getting that because it the indictment, a SO the the Court is just laying out there's no need to put all of the defense would to Jane here as in the offense into the statement of the th defens lsewhere, but an iss ue in the parties' things like the name the name Jeffrey Epstein should all e recitation of the elements. think the t's in the "to wit" clause of nd the law is quite clear -- and I have UTHERN D STR CT REPORT ERS, (212) 805-0300 PG ew DOJ-OGR-00014325