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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 LCT1MAX1 the conspiracy co here to generaliz going to be applied later to the conspiracy counts, right? But this is the subst says first that t unts come later Filed 08/10/22 Page 21 of 95 2759 e the wording o antive count, and it he dei ld fF we look at the line 5, it enticed or coerced an individual to travel commerce. The in dividual The defense requ replace that with Florida to New Yo [ think there is an attempt £ the elements because it's fendant knowingly persuaded or induced or in interstate in the substantive count is Jane. st is for it to say not "an individual," "Jane to travel in in terstate commerce from rk, as alleged in the indictment." THE COUR MR. ROHRI will be confused. BACH: So, your T: Mr. Rohrbach. Honor, section, it says this relates to Jane. like it to say it summary, that wou relates solely ld be fine, but the elements of t the factual predi elements. I thin Mr. Everdell can proposed requests to charge is whether Jane, travel to N be included in th defense is getting that because it the indictment, a SO he offense and cates of the of the Court is just laying out there's no need to put all of I don't think the jury Both in the summary and later on in this the defense would to Jane here as in the th Fense into the statement of the defens k here and elsewhere, correct me, but an issue in the parties' things like the name ew York, the name Jeffrey Epstein should all e recitation of the elements. I think the t's in the "to wit" clause of nd the law is quite clear -- and I have UTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016947