DOJ-OGR-00014699.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 LCRVMAXT question becau MR. EVERDELL: clear. They s If the de ay: Document 773 they haven't identified a Your Honor, Filed 08/10/22 of Jane's retu but rn flight, not the only evidenc the one in the we have of a flight logs, and it I think they've been flight to New Mexico. Page 13 of 29 3130 flight here. fairly fendant aided in the transportation The Flight to New Mexico with Jane is is a Flight to New Mexico. And so the return flight would be some other flight besides the flight to New Mexico. She is also alleged that -- and to be honest, I think it was a little unclear what may have happened in New Mexico based on her testimony; but if there was any illegal sexual conduct, the flight to New Mexico, this is what they are debating, because they say, but not the flight to New Mexico, where/if the intent was for Jane to engage in sexual activity. Okay. So it seems that the jury is deliberating or at least trying to decide whether the flight to New Mexico was for the purpose of engaging in illegal sexual activity. And they are confused t could that be the basis alone Answer is no, hat the return because that r eturn of illegal sexual activity. Flight is not Flight that happens after that, for a conviction on Count Four. for the purpose MS. MOE: Your Honor, at the very least, the answer to this can't be no, because a jury could infer intent to engage in sexual conduct and the return of a flight in aiding and abetting that. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014699