DOJ-OGR-00016953.pdf

--- Page 1 --- **Document Text Extraction** **Header:** Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 27 of 95 LCI1MAX1 **Page Number:** 2765 **Text:** induced the travel, and a separate requirement that she caused the travel. And there's no causal obligation or causal requirement in the statute above and beyond the persuasion, inducement type causal requirement. MR. EVERDELL: I mean, your Honor, if the objection is to the preamble by saying, "This element is satisfied only if," we could modify that a bit, if the government's saying that is too strong, but the guts of the suggestion is that the persuasion, inducement, or enticement must have caused the individual to travel in interstate commerce, as alleged in the indictment. THE COURT: I mean, I've seen this charge in a variety of cases. I've never seen that language. This decision is 2010. Have you ever seen it in a charge? MR. EVERDELL: I can't say that I have, your Honor. But it is interpreting the very words of the statute that are at issue here, and I don't think this is the way that -- the proposal I'm proposing is not trying to belabor the point, but it is trying to raise the issue of causation. THE COURT: I mean, the opinion includes further definition of the words that are subject to the ordinary meaning, the paragraph above that you point to. MR. EVERDELL: Your Honor, I'll add that it is possible to be persuaded, induced or enticed, and then not actually travel. I mean, the persuasion does have to cause the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016953