DOJ-OGR-00016936.pdf

--- Page 1 --- **Case 1:20-cr-00330-AJN** **Document 765** **Filed 08/10/22** **Page 10 of 95** **LCI1MAX1** **THE COURT: Mr. Rohrbach?** **MR. ROHRBACH: Your Honor, this is a place where the defense confuses conspiracy violations and substantive violations. There does not have to be a proven violation of New York law as to any of the minor victims. It just has to be an agreement to accomplish that purpose. Carolyn, for instance, was invited to travel by the defendant. The jury can readily find that that invitation to travel included an invitation to New York, where the abuse would continue, as it did for Jane. Annie was in fact transported by the defendant** **Epstein to New Mexico and New York. The jury could readily find that that was a conspiracy that existed, and as part of that grooming conduct, the plan would be to continue to abuse her, including back in New York. These are available inferences to the jury, and that's all that's required for the conspiracy count.** **THE COURT: That's precisely why there was a different limiting instruction for Annie than there was for Kate.** **MR. EVERDELL: Well, your Honor, I would dispute the facts a little bit there, because they said that Carolyn's testimony was that she was invited to travel to the island. She was not invited to travel anywhere; she specifically testified she was given an invitation to the island. That's not travel to New York. And her mother said she couldn't be able to go. So I don't think that is evidence -- if the object** **SOUTHERN DISTRICT REPORTERS, P.C.** **(212) 805-0300** **DOJ-OGR-00016936**