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be N Ww ws Oo OY ~] oO WO Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 19 of 95 2757 LCT1MAX1 MR. EVERDELL: Or in brackets because it's an addition to the statutory text. MR. agree with this one. ROHRBACH: Your Honor, the government does not had been coerced for the enticement counts. The jury could conclude that the minors There's expert testimony from Dr. Rocchio about how these relationships sort of evolved; how, toward there's testimony from Jane in the record about the end of her relationship with Mr. Epstein, she felt Like she was compelled to continue answering the phone and would drop everything because she had no other choice. I think the jury could conclude that these victims were coerced. "Coercion" in this context just bears its ordinary and natural meaning, and there's no reason to delete it MR. EVERDELL: Well, your Honor, from the charge. agree I know we give normal meanings to these words, and coercion in my normal meaning implies some sort of force, or at least of violence or something, and there's no evidence of that MR. free to mak e in the record. to the jury. THE notion that G GQ COURT: Well, what's the legal ROHRBACH: It's an argument that the defense is basis for the coercion as used here textually MR. requires force? EVERDELL: Your Honor, as in Sand, they just say "given the normal everyday meaning." It's not particularly helpful, bu t guess that can differ by person. My normal everyday meaning of "coercion" means some sort of force being SOUTHERN DISTRICT REPORTERS, (212) 805-0300 DOJ-OGR-00016945