DOJ-OGR-00016950.pdf

--- Page 1 --- **Document Extraction** **Case Information:** * Case Number: 1:20-cr-00330-AJN * Document Number: 765 * Filed Date: 08/10/22 **Page Information:** * Page Number: 24 of 95 **Text Extraction:** 1. word "coerced" we would like to remove. We understand that's been overruled by the Court. 2. Okay. But there is some additional language we would propose at the end of line 6, and this is something that I raised I think in a letter submission in -- or not in a letter -- orally at the Rule 29 argument. It's based on U.S. v. Broxmeyer, which, as I argued to the Court at the Rule 29 argument, the words "persuade," "induce," and "entice" are words of causation and they need to cause an effect, and so what we would propose after the sentence, "The terms 'persuaded,' 'induced,' 'enticed,' and 'coerced' have their ordinary, everyday meanings," we would propose adding the following language: "This element is satisfied only if the 'persuasion,' 'inducement,' or 'enticement' caused Jane to travel in interstate commerce as alleged in the indictment." We're basing that on U.S. v. Broxmeyer, interpreting those words from a different but related statute. 3. THE COURT: Give me one moment. 4. MR. EVERDELL: I have a copy of Broxmeyer, your Honor, if you'd like to see it. 5. THE COURT: Sure. I'll take it. 6. MR. EVERDELL: Your Honor, I believe it's on page 125 of the opinion. 7. THE COURT: Okay. The relevant language. 8. MR. ROHRBACH: Your Honor, this is not just a **Footer Information:** * Southern District Reporters, P.C. * Phone Number: (212) 805-0300 * Document ID: DOJ-OGR-00016950 **Note:** * The document appears to be a transcript of a court proceeding, with the text extracted from the image. The formatting and layout of the text are preserved as closely as possible.