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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 16 of 95 2754 LCI1MAX1 THE COURT: Yes. MR. EVERDELL: Your Honor, I'm sorry. Could we just return to page 15. THE COURT: Sure. MR. EVERDELL: Line 23. THE COURT: Okay. MR. EVERDELL: There, it says -- and it's also on the next page, indictment sex traffi but we'll get to that. It says, "Count Five of the charges the defendant with conspiring to engage in cking of minors. And the word "minors" depends on jurisdicti got allega conspiracy to create on, and it creates a lot of ambiguity because we'v tions, especially because the time period of the , 2001 to 2004, you know, the word "minors" is going an ambiguity, and it raises issues with the age of consent, because you're not a minor unless, you know -—- THE COURT: You want to change it to an individual under the age of 17? MR. EVERDELL: Yeah, either under the age of 17 or under the age of consent. MR. ROHRBACH: Well, your Honor, first, for the sex trafficking counts, the relevant age of consent is 18. ik HE COURT: Right. Sorry. Thank you. M in the language of the statute itsel R. EVERDELL: Yeah, actually, that's right. That's MR. ROHRBACH: Yeah. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016942