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Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 40 of 95 2778
LCI1MAX1
MR. EVERDELL: Understood, your Honor.
Okay. Next page, your Honor?
THE COURT: Yes.
MR. EVERDELL: The next one we have is on page 26.
THE COURT Okay.
MR. EVERDELL: We would reiterate, just for the
purposes of the record, of including "Jane" as opposed to "an
individual" or "the individual." That's been overruled, but we
will ask that the word "solely" be included on line 12, so,
"Count Four also relates solely to Jane."
MR. ROHRBACH: No objection.
THE COURT: Okay. We'll make that change. And my
clerk tells me we missed an "and foreign" on page 25.
MR. EVERDELL: Yes, yes. So we do have to go back to
page 25. So on line 5, there's an "or foreign."
THE COURT: So that will be with the ellipses. So
page 25, line 5, "interstate... commerce..."
MR. EVERDELL: Yes. And there's one other thing on
that page, your Honor, forgot to mention.
THE COURT: Just a moment.
Okay. Go ahead.
MR. EVERDELL: Your Honor, on line 4 of that same
page, 25, I know it's a quote from the statute, which does say,
"knowingly transports any individual under the age of 18," but
this is the issue with New York law being under the age of 17,
SOUTHERN D
STR
CT REPORT
ERS,
(212)
805-0300
2)
DOJ-OGR-00016966