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Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page13o0f13 Page 13 the Court make sure the jury understands its point: the instruction should say that Minor Victim-3 was above the age of consent at all relevant times, but it should also say expressly that the jury can consider her evidence as direct evidence or for all of the permissible purposes under Rule 404(b). That result, and the admission of her testimony, is entirely proper. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: ___s/ Alison Moe Lara Pomerantz Andrew Rohrbach Assistant United States Attorneys Souther District of New York Cc: Defense Counsel (By E-mail) DOJ-OGR-00007430