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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 Document 779 Filed 08/22/22 Page 25of101 25 M6SQmaxl THE COURT: It's not dated November 2004; am I right? It's on a page that has dates surrounding it of December, November. MS. MOE: Yes, your Honor, all of the dates surrounding the message would be after November 1, 2004. The neighboring dates are November 13. There's a date in December. And I think looking at the message pads as a whole, it tells us they're dated essentially sequentially. THE COURT: Is there any way to tell -- again, this is very technical if MS. physical book. page before and Our view is neighboring as we noted with Eps the combination of da in MOE: El Af Your Honor, just have the sheet in ter, 1] our brief the defendant's burden to est ld the Court would like to the defendant was still which they've no conspiracy, We think that that the tes conspiracy was ongoing more than meets this burden. timony o1 tes tell us it's November of tein during this exact same time period. tablish withdrawal fF the messag it's October and November? I'd be happy to take a look at front of itself 2004. me to see the examine it. and the In addition, traveling at the message pads, tempted to do, the Flight records, THE COURT: Okay. MR. EVERDELL: that. do pick SOUTHERN D Your Honor, if up on what the Court is saying, STR GI PORT ERS, Ps (212) 805-0300 Again, it's from an ongoing nor could they. the fact F a crime victim Carolyn was that the could just respond to and we agree DOJ-OGR-00014772