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20 a1 22 23 24 25 Case 22-1426, Document oO N399 3536039, Page138 of 217 Me6eSQmaxl evidence. MS. MOE: No, your Honor. I think that, and I don't mean to be -- the conspiracy was still live at the end of 23 our point is that 2004, THE COURT: But, see, just in that sentence, and we know that because in fact the conspiracy was still ongoing beyond th conspiracy was going on beyond that, what you point to, think -- and tell me if I should look at somet thing else, but what you point to to make that argument is definitionally non-conspiracy conduct. MS. MOE: No, your Honor, in part becaus step back and discuss the framing of the issue. well, to The question is whether a conspiracy was still ongoing throughout 2004. And the key thought tells us it's the defendant's burden to show that she withdraw from the conspiracy if it was ongoing. The question is in framing it, when did this conspiracy end. We know that it was still live as of the end of F 2004, in fact, because, among other reasons, Carolyn testi fied that she was continually going to Epstein's house through age 17 and through age 18, which would have been throughout the duration of 2004 and 2005. The government is not required to show that any conspirator took an action in between those specit because the question is when did the conspiracy termina it still live at the end of 2004? And th videnc Fic dates te? Was here shows SOUTHERN DISTRICT REPORTERS, P.C.°ee° (212) 805-0300 DOJ-OGR-00021568