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be NO Ww ws Oo OY ~] oO Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LBNAMAXTps MR. EV defense's position that the Court's Document 536 BPRDELL: Yes, statement of law. is cumbersome, rather than to And identified the alleged events think the government's It's concise, your Honor Filed 12/10/21 Page 32o0f43 32 . © mean, it's the instruction is a correct it's clear, the issues for the jurors as opposed to cont fuse the issues. I and will clarify instruction is exactly the opposite. It it is difficult to follow, and it will confuse clarify. [ will just point out, I think your Honor correct example, which is Accuser 2, which is that took place in New the age of consent And so this illustra th a conspiracy wher of New York law with acts tha jurisdictions which were lega illega Mexico when she was above for those acts in New Mexico. tes the problem of trying to prove l sexual activity is a violation t took place in other l and have nothing to do with New Under New Mexico law. I'm sorry. I Fore, your Honor, if fy to these events that took place they're legal under New York law —- ume that the York law. So as I think you've discussed bet the witness is going to testi in New Mexico, even though there's no issue ther they're going to -- THE COURT: Not under New York law. MR. EVERDELL: misspoke. Under New Mexico law. THE COURT: Right. MR. EVERDELL: They're going to ass SOUTHERN DISTRICT REPORTERS, (212) 805-0300 DOJ-OGR-00008342