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be N Ww ws Oo OY ~] oO WO Ww Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 9 of 95 2747 LCT1MAX1 sexual activity as charged in the indictment, which is a reference to the violation of New York law, because that is the theory we're proceeding under. With respect to Carolyn, there was no limiting instruction, but it's evident we were talking about Florida conduct. There is no violation of New York law there. So the only evidence we have that goes to -- that actually establishes a violation of New York law, which is the object of this conspiracy, and the object of the transportation conspiracy, is what Jane said. Now the Court did instruct the jury that they can consider the testimony of Kate and of Annie for whatever relevant purpose they see fit, and I suppose that could be vidence of a conspiracy, correct, but for them to actually a OY 20 21 22 23 24 25 convict on this, they have to believe that somebody committed a violation of New York law, and that relates solely to Jane, and so we don't think there are no multiple alleged victims of this conspiracy other than Jane that's been established by the evidence at trial. So we believe while they may be able to consider the testimony of Annie and Kate as evidence of some sort of relevant evidence that speaks to this conspiracy, that is not they are not victims of this conspiracy, there was no violation of New York law that they testified to, and that is Jane alone. So this count relates solely to Jane, as does the substantive count, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016935