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20 21 22 23 24 25 Case 22-1426, Document Taott |. 3475901, Page11 of 221 | A211 | 1 LCRVMAXT 3130 question because they haven't identified a flight here. MR. EVERDELL: Your Honor, I think they've been fairly clear. They say: If the defendant aided in the transportation of Jane's return flight, but not the flight to New Mexico. The only evidence we have of a flight to New Mexico with Jane is the one in the flight logs, and it is a flight to New Mexico. And so the return flight would be some other flight besides the flight to New Mexico. She is also alleged that -- and to be honest, I think it was a little unclear what may have happened in New Mexico based on her testimony; but if there was any illegal sexual conduct, the flight to New Mexico, this is what they are debating, because they say, but not the flight to New Mexico, where/if the intent was for Jane to engage in sexual activity. Okay. So it seems that the jury is deliberating or at least trying to decide whether the flight to New Mexico was for the purpose of engaging in illegal sexual activity. And they are confused that the return flight that happens after that, could that be the basis alone for a conviction on Count Four. Answer is no, because that return flight is not for the purpose of illegal sexual activity. MS. MOE: Your Honor, at the very least, the answer to this can't be no, because a jury could infer intent to engage in sexual conduct and the return of a flight in aiding and abetting that. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00020837