DOJ-OGR-00016947.pdf

--- Page 1 --- The image displays a document with text, which appears to be a page from a court transcript. The text is presented in a typewritten format, with each line numbered and indented. Here is the extracted text: **Header:** * Case 1:20-cr-00330-A.JN * Document 765 * Filed 08/10/22 * Page 21 of 95 **Text:** 1. the conspiracy counts come later, I think there is an attempt here to generalize the wording of the elements because it's going to be applied later to the conspiracy counts, right? But this is the substantive count, and if we look at the line 5, it says first that the defendant knowingly persuaded or induced or enticed or coerced an individual to travel in interstate commerce. The individual in the substantive count is Jane. 2. The defense request is for it to say not "an individual," replace that with "Jane to travel in interstate commerce from Florida to New York, as alleged in the indictment." 3. THE COURT: Mr. Rohrbach. 4. MR. ROHRBACH: So, your Honor, I don't think the jury will be confused. Both in the summary and later on in this section, it says this relates to Jane. If the defense would like it to say it relates solely to Jane here as in the summary, that would be fine, but the Court is just laying out the elements of the offense and there's no need to put all of the factual predicates of the offense into the statement of the elements. I think here and elsewhere, the defense -- Mr. Everdell can correct me, but an issue in the parties' proposed requests to charge is whether things like the name Jane, travel to New York, the name Jeffrey Epstein should all be included in the recitation of the elements. I think the defense is getting that because it's in the "to wit" clause of the indictment, and the law is quite clear -- and I have **Footer:** * SOUTHERN DISTRICT REPORTERS, P.C. * (212) 805-0300 * DOJ-OGR-00016947 Note: The text appears to be a continuation of a conversation between the judge, prosecutor, and defense attorney, discussing the wording of the indictment and the elements of the offense.