DOJ-OGR-00014307.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 765** **Filed 08/10/22** **Page 3 of 95** **2741** **LCI1MAX1** **MR. EVERDELL: I can pull this up a little bit?** **THE COURT: -- if I'm going to hear from you a lot.** **But yes, pull up the mic and -- yes. First page, Mr. Everdell.** **MR. EVERDELL: Defense's first page is page 15.** **THE COURT: Okay. Line?** **MR. EVERDELL: Well, we'll start with line 8 and 9.** **THE COURT: Okay.** **MR. EVERDELL: So this was the summary of the indictment charge, your Honor.** **THE COURT: Yes.** **MR. EVERDELL: And on 8 and 9, there's a reference to travel to both interstate and foreign commerce. I think throughout the charge there's a bit of an inconsistency.** **Sometimes we're talking about just interstate, sometimes we're talking about interstate and foreign. I actually don't think that there's any evidence, especially with respect to Count One or the Mann Act charges or any of them, we're talking about "and foreign commerce." I think it's interstate commerce, so I don't think the "and foreign" is necessary.** **THE COURT: I think we have -- Mr. Rohrbach?** **MR. ROHRBACH: Your Honor, this actually relates to the government's later request, but the government's view is that there are flight records that show Virginia Roberts traveling with the defendant and Jeffrey Epstein overseas while she is 17, I believe, and so that would be sufficient, at least** **SOUTHERN DISTRICT REPORTERS, P.C.** **(212) 805-0300** **DOJ-OGR-00014307**