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be NO Ww ws Oo OY ~] oO Ke) a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LBITMAX3 this testimony as direct Document 465 Filed 11/15/21 Page 79 of 127 79 So on trafficking, the government would seek to have videnc trafficking count, because the individual of with respect to the legal age in all relevant jurisdictions was under the age of 1 to have to spell it out for me. MS. MOE: Ez Yes, your Honor. 8. You're going fense were to argue that the defendant didn't know that vic LO have done the trafficking count were under th age o tims with respect f 18 or wouldn't this if they were under 18 or that she did not know that Epstein had a preference for underage girls or his sexualized massages were with girls under the age of 18, this would certainly speak to didn't know that sexualized, I think the testimony o that issue would cer In particular, if the det THE COURT: Right. Okay. that issue. tainly make that all the more relevant. fFendant were to argue that she t the massages she was arranging were f the victim speaking to I'm not sure the government had previously argued this constituted direct vidence of the trafficking count, is that right? MS. MOE: Your Honor, I would have to review our briefing. I believe we said that it was direct evidence of the charged crimes. apologize if we were vague about that, but our view is the entire course oi de su fendant's role and knowledge, fficient. fF conduct speaks to the and the proof here is mutually SOUTHERN DISTRICT RE PORT (212) 805-0300 ERS, Ps DOJ-OGR-00007130