DOJ-OGR-00016944.pdf

--- Page 1 --- **Case 1:20-cr-00330-AJN** **Document 765** **Filed 08/10/22** **Page 18 of 95** **LCI1MAX1** **2756** **1** **THE COURT:** Okay. Have we made it to 17? **MR. EVERDELL:** We've made it to 19, in fact. **THE COURT:** 19. Wow. Progress. **MR. EVERDELL:** Page 19 is the next one, your Honor. **THE COURT:** Okay. Go ahead. **MR. EVERDELL:** First, on line 5, there's another "or foreign," which we can omit. **THE COURT:** Okay. Let me just look. **Yeah. Okay.** **MR. ROHRBACH:** It would need to be ellipses since this is the statutory text, but that's fine with the government. **THE COURT:** So we'll do, page 19, line 5, it will read, "Travel in interstate... commerce," cutting "or foreign" and replacing with the ellipses. **Okay. Next page.** **MR. EVERDELL:** Same page, your Honor, line 4. **Don't worry. I tried to be efficient about this.** **We'll go quickly.** **THE COURT:** That's fine. **MR. EVERDELL:** Line 4. There is the inclusion of the statutory text "or coerces," and since we don't have any evidence of coercion, our proposal would be to add -- have it read "knowingly persuades, induces, or entices... any individual." **THE COURT:** Or in brackets. **SOUTHERN DISTRICT REPORTERS, P.C.** **(212) 805-0300** **DOJ-OGR-00016944**