DOJ-OGR-00007134.pdf

Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 83 of 127 83 LB1TMAX3 she felt, in her words, sexually abused in these circumstances, that she was in fact engaging in illegal conduct. And it raises a real problem that the jury will convict on a false premise, on a legally incorrect assumption that the conduct that was occurring was illegal when it wasn't. So your Honor, we object to her testimony for any purpose at this trial. MS. MOE: Thank you, your Honor. Just to taking those points one by one, with respect to the time difference, we think that it is nonetheless relevant with respect to the sex trafficking counts. THE COURT: Am I right -- point me to the page. It's not argued in the papers. MS. MOE: I apologize, your Honor, we should have been more specific, and I do apologize about that. I do think that the way we framed it was about preference for girls under the age of 18 and about the course of conduct, but I apologize, we should have been more specific about that. But with respect to the timeframe and the course of conduct, I think the jury would be free to conclude, based on this direct evidence, that in 2002 and 2003 when Minor Victim-4 was being trafficked, that the defendant knew that Epstein had a preference for girls under the age of 18 and knew that he would engage in sexual contact with them because she knew in 1994 when she was involved in transporting Minor Victim-1 that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007134