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Case 22-1426, Document 58,_02/28/2023, 3475901, Page20 of 221 A-220 3139 LCRVMAXT which is the substantive transportation count, which, as we know, has to deal with the violation of New York law. And they and can she be found are talking about flights to New Mexico; guilty on the second element of Count Four regarding these flights to New Mexico. So I think we may have to respond to the jury on that score as well, which is the fact that they have to be considering New York events for Count Four, rather than -- or which wouldn't occur in New Mexico violations of New York law, for there to be a conviction on Count Four. MS. MOE: [ think Your Honor, that's exactly why we the proposed directing the jurors to the entirety of instruction, which says just that. The second paragraph of that same instruction reminds the jury, as the instruction does throughout, that we're talking about New York Penal Law, Section 130.55. And so I think our proposal remains the same that they be r which the instruction, ferred to the entirety of includes that language, among other aspects of this particular 20 21 22 23 24 25 element. THE COURT: Yes. MS. STERNHEIM: Judge, may I be heard for a moment? THE COURT: Sure. MS. STERNHEIM: think the fact that the jury has mentioned New Mexico regarding a count tha York is not just cleared up by referring t t pertains to New hem to the SOUTH ERN D STR CT REPORT ERS (212) 805-0300 , PLC. DOJ-OGR-00020846