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Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 10 of 95 2748 LCI1MAX1 1 THE COURT: Mr. Rohrbach? 2 MR. ROHRBACH: Your Honor, this is a place where th 3 defense confuses conspiracy violations and substantive 4 violations. There does not have to be a proven violation of 5 New York law as to any of the minor victims. It just has to be 6 an agreement to accomplish that purpose. Carolyn, for 7 instance, was invited to travel by the defendant. The jury can 8 readily find that that invitation to travel included an 9 invitation to New York, where the abuse would continue, as it 10 did for Jane. Annie was in fact transported by the defendant 11 Epstein to New Mexico and New York. The jury could readily 12 Find that that was a conspiracy that existed, and as part of 13 that grooming conduct, the plan would be to continue to abuse 14 her, including back in New York. These are available 15 inferences to the jury, and that's all that's required for the 16 conspiracy count. 17 THE COURT: That's precisely why there was a different 18 limiting instruction for Annie than there was for Kate. 19 MR. EVERDELL: Well, your Honor, I would dispute the 20 facts a little bit there, because they said that Carolyn's 21 testimony was that she was invited to travel to the island. 22 She was not invited to travel anywhere; she specifically 23 testified she was given an invitation to the island. That's 24 not travel to New York. And her mother said she couldn't be 25 able to go. So I don't think that is evidenc if the object SOUTHERN DISTR CT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016936