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Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 36 of 95 2774 LCI1MAX1 1 can hand it up. 2 THE COURT: Sure. 3 MR. EVERDELL: And your Honor, as you consider that, 4 there is one proposed addition just want to request to what's 5 on that page, but I want to handle that slightly separately. 6 THE COURT: The representation is these are -- 7 MR. EVERDELL: Yeah. 8 THE COURT: -- my limiting instructions given before 9 Kate and Ms. Farmer testified, and you're asking for 10 inclusion -- repetition of those limiting instructions where 11 the violation of New York criminal law is provided. 12 MR. EVERDELL: That's correct, your Honor. And we 13 would propose just putting it at the end after the discussion 14 that's already there. 15 THE COURT: Mr. Rohrbach. 16 MR. ROHRBACH: I think that among other things, your 17 Honor, I think that would be -- the instruction as you've 18 crafted it is a correct statement of New York law and the 19 relevant issues. Adding these instructions would be quite 20 confusing to the jury. The jury has already heard them. This al is the place where there's no reason to give the Kate 22 instruction because these jury instructions state specifically 23 that the jury may not convict based solely on overt acts that 24 relate to Kate, and so there is no risk, when these full set of 25 instructions is read to the jury, that they will think that SOUTHERN D STR CT R EPORTERS, P.C. (212) 805 -—0300 DOJ-OGR-00016962