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20 a1 22 23 24 25 Case 22-1426, Document ON 301 3536039, Page137 of 217 Me6eSQmaxl To post conspi like to ask you to draw my attention to what record spec MS. As that the case law is that OL the cons the last da establish a some extent, racy conduct, MOE: Yes, a threshold matter, and the government points, that concerns me. 22 think, to And so I would ifically speaks to November and your Honor. the piracy. In te of the conspiracy? bout the final date? other words, taking actions periodically over time, the question is what What in the trial 2004. December of government's understanding is the end date if the conspirators are the question is what is does the trial evidence And here the trial evidence was that the conspiracy was ongoing through all of 2004 and ante 2005. TH E COURT: But to make that point, I think you're relying on post conspiracy evidence. And so it's not just what MS. MOE: No, that exceeds the dat THE COURT: birthday. MS. MOE: Yes, THE COURT: here on Carolyn being under 18 that's why I not only because it goes past what because [ think legally you're poin see what you're point your Honor. We're relying on evidence in the indictment, It exceeds also but it -- the date of Carolyn's 18th your Honor. for its continuation. ting to as post the indictment charges -—-— —- but by a conspiracy that is dependent And so conspiracy, the indictment charged, but ting to non-conspiracy SOUTHE RN D STRICT REPO! RTERS, PeGu 0 12) 805-0300 DOJ-OGR-00021567