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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 is about. the charge is about that particular element. guesswork here makes this more cont confusing. particular issue. Document 773 I think, as the Court pointed out, some aspects of this note are about aiding and abetting. And so we think the sai Filed 08/10/22 Page 17 of 29 3134 And so the question is about the element; I think more fusing and not less And so even referring the jury just to instruction number 21 leaves out that aspect of the jury's deliberations and their determination on this Fest course is to provide the jury with applicable law in this area, and they can particular instruc find the facts as MR. question about aid and abet not Ms. Maxwell had any travel -- they are talking about EVERDELL: they see tions. Your Honor, ting, think that much is pret THE COURT: fe) this found guilty aided in the That's not legally accurate, transportat MR. it has to be across state a significant or motiva Bu CoO EVERDELL: the CY fligh ts to and from New Mexico. fit and as they apply to these I don't think this is a broadly speaking. I think clear from the note. And whether or thing to do wit th arranging that Your Honor, the tion to New Mexico. is it? t your legal contention is she can't be unt unless the jury concludes that she instruction itself says ting purpose for the travel lines. THE COURT: Right. SOUTHERN DISTRICT REPORTERS, (212) 805-0300 PG ew DOJ-OGR-00014703