DOJ-OGR-00001948.pdf

Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 71 of 91 1 THE COURT: All right. Thank you, Mr. Cohen. 2 Ms. Moe, would the government like a brief reply? 3 MS. MOE: Yes, your Honor. Thank you very much. 4 Your Honor, I want to begin by addressing head on the 5 notion that the government's presentation in this case is 6 somehow about spins or about throwing dirt or about the media. 7 Your Honor, my colleagues and I are appearing today on behalf 8 of the United States Attorney's Office of the Southern District 9 of New York. Our presentation of the defendant's conduct is 10 detailed in an indictment that was returned by a grand jury in 11 this court. These are the facts. It is not dirt. It is not 12 spin. That is the evidence and that is what we have proffered 13 to the court. 14 And the notion that anyone could read the indictment 15 that has been returned in this case and now reach the 16 conclusion that an adult woman, cultivating the traffic of 17 underage girls, knowing that they will be sexually abused and 18 exploited by an adult man, and conclude that that is chilling 19 conduct, that is, on the face of the indictment, your Honor. 20 Turning to the facts we have proffered to the court 21 about the defendant's finances, and particularly about the 22 defendant's conduct in hiding, it appears, your Honor, that it 23 is undisputed that the defendant was living in hiding and took 24 those actions. There cannot be any spin or characterization of 25 this spin. Those are the facts that appear to be undisputed. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001948