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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-PAE LCSCMAXT request of th that, e letter, but it will not take very THE COURT: Okay. Document 775 Filed 08/10/22 Page 6 of 16 3152 if I could make a brief record on long. And so ther made yesterday at the tim record that you put in the e is the record that you the question came. There is the letter this morning that came in late -- early this morning that I revie just discussed. So, to the at the apple, record. extent you' wed this morning that we re seeking a third bite go ahead. MR. EVERDELL: I'm simply looking to fill out the I understand it's been rejected by the Court. [ think from the defense point of view, I think two things are very clear from considering whether or not substantive of fense in Coun this note. One is that the jury is they can convict Ms. Maxwell on the t Four based solely on events that took place in New Mexico and traveled to and from New Mexico. that don't necessarily derive but THE I understand COURT: There are a number of assumptions in that MR. And I that is your position. from the meaning of that letter, EVERDELL: Understood, your Honor. think the second point is that they are looking at the instructions that they have been given thus far because they r ECHe the second element of Count Four. So they're looking at that instruction and they ar confused by those instructions. e unclear, they are They are not sure whether or not -- those instructions don't inform them that, in fact, SOUTHERN DIS TRICT REPORT BRS, Pes (2 12) 805-0300 DOJ-OGR-00017339