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Case 22-1426, Document 58_02/28/2093, 3475901, Page10 of 221 A-210 Fican 3129 ngaged in illicit t or motivating purpose Epstein wasn't present; it's just a That would not be a significant She is just presumably going home, but Jan licit sexual activity. lieve it, is that she for some purpose to engage in sexual "s testimony. But Returning is it's going somewhere away from where —- at least in the record, the evidence in the Epstein was presumably in New So I don't think that tivating purpose. That travel ther purpose. I don't believe this note is flight we're talking about. The note Fied return flight, and then urse here 1s to New Mexico. Then there's It is unclear which of the to refer the jury to LCRVMAXT 1 across state lines has to be that Jane e 2 sexual activity. There is no signiit 3 of a return trip where Mr. 4 return trip from New Mexico. 8 or motivating purpose. 6 is not for the purpose of engaging in i] 7 The testimony, if we are to bel 8 went to New Mexico 9 activity, that's if you believ 10 returning from there is not that purpose. 1] returning, or it's going somewhere else; 12 13 record, if there is any —- 14 Mexico. This is her leaving New Mexico. 15 qualifies as a significant or mot 16 across state lines is for some ot 17 MS. MOE: Your Honor, 18 that clear about what 19 begins by talking about an unspeciit 20 it turns to talking about a flight 21 a modifying clause about intent. 22 two flights we are now modifying. 23 think the safest co 24 the elements of 25 they may be talking about is sort of SOUTH the crime. I think guessing at what flight fF beyond the reach of this ERN DISTRICT REPORT (212) 805-0300 ERS, P.C. DOJ-OGR-00020836