DOJ-OGR-00018914.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 52 of 262 1757 LC8VMAX2 Shawn - direct 1 MS. MOE: Your Honor, with respect to the disclosure question, I just wanted to note, the issue for disclosure was who the government would be arguing at trial were the victims here. We don't intend to argue at closing that there's an additional victim Amanda. This is being offered as direct evidence as corroborative testimony of the account of the victims here. THE COURT: Well, direct evidence only if you're suggesting she's a victim of the conspiracy. So that would violate that order. And it's corroborative only if the age matched up. MS. MOE: Your Honor, our view is that it's direct evidence because it corroborates her account of who she was bringing. THE COURT: Then what's the purpose of the -- sorry. What's the purpose of the age? The testimony yesterday was she believes she was 17. Sustained. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018914