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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 which is the substan know, Document 773 Filed tive transportation count, has to deal with 08/10/22 which, fF New York law. the violation oft are talking about guilty on the second element of So score as well, which fligh flights to New Mexico. I think we may have is considering New York events violations of New York law, MS. MOE: proposed directing the jurors to instruction, for there to be a conviction on Count Your which says just that. ts to New Mexico; the fact that think Honor, same instruction reminds the jury, And so that throughout, Section 130.55. that they be ref rred to the en includes that language, that we're talking about New York for Count Four, the entirety of The second pa I think our proposal rema they have to be Four. the among other aspects of element. THE COURT: Yes. MS. STERNHEIM: Judge, may I be heard THE COURT: Sure. MS. STERNHEIM: think the fact that tirety of Page 22 of 29 and can she be ragraph of the instruction, 3139 as Wwe And they found Count Four regarding these to respond to the jury on that rather than -- or which wouldn't occur in New Mexico that's exactly why we as the instruction does Penal Law, ins the same which this particular mentioned New Mexico regarding a count York is not just cleared up by rei for a moment? the jury has that pertains to New ferring them to the SOUTHERN CT RE DISTR PORTERS, Piss (212) 805-0300 DOJ-OGR-00014708