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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 Document 465 Filed 11/15/21 Page 81 of 127 81 LB1TMAX3 That really was not spelled out in the briefing. THE COURT: think for sure it wasn't, because just hearing it for the first time, it strikes me as having potential plausibility. That was not present in the papers, so certainly will MOFre . MR. teed up, there is a time di need brie EVERDELL: can I would have addressed it. betw assure you if But Fing and to think about that question it had been really would note that n the Mann rence and the sex traf The sex traf particular individual time 2001 to 2004 is was well over the age of place in '94 and '95 well past the age of jurisdictions. going on. when she' consent in any of I don't see how it is probative of Ficking counts. Ficking counts are 2001 to 2004, Act conspiracies and this She's alleg s 17 and 18. consent by the ing events that took 2001 to 2004 is thes e relevant the defendant's intent -- when someone is presumably allegedly engaging in Sex a perfectly legal knowledge, or any of And by the way, there are we talking about It seems lik cts, the above of '"s no al how that is probative of intent, a sex tra legation that sex tra icking? Fficking conspiracy. she got paid, so how the government is trying to take an episode of legal conduct and make it sound salacious for the jury and use it as direct evidence of conspiracies for which it SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00007132