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    "page_number": "81",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 81 of 127\nLB1TMAX3\n1 That really was not spelled out in the briefing.\n2 THE COURT: I think for sure it wasn't, because just\n3 hearing it for the first time, it strikes me as having\n4 potential plausibility. That was not present in the papers, so\n5 I certainly will need briefing and to think about that question\n6 more.\n7 MR. EVERDELL: I can assure you if it had been really\n8 teed up, I would have addressed it. But I would note that\n9 there is a time difference between the Mann Act conspiracies\n10 and the sex trafficking counts.\n11 The sex trafficking counts are 2001 to 2004, and this\n12 particular individual was well over the age of consent by the\n13 time 2001 to 2004 is going on. She's alleging events that took\n14 place in '94 and '95 when she's 17 and 18. 2001 to 2004 is\n15 well past the age of consent in any of these relevant\n16 jurisdictions.\n17 I don't see how it is probative of the defendant's\n18 intent -- when someone is presumably allegedly engaging in\n19 perfectly legal sex acts, how that is probative of intent,\n20 knowledge, or any of the above of a sex trafficking conspiracy.\n21 And by the way, there's no allegation that she got paid, so how\n22 are we talking about sex trafficking?\n23 It seems like the government is trying to take an\n24 episode of legal conduct and make it sound salacious for the\n25 jury and use it as direct evidence of conspiracies for which it\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007132",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 81 of 127",
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      "content": "LB1TMAX3",
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      "content": "1 That really was not spelled out in the briefing.\n2 THE COURT: I think for sure it wasn't, because just\n3 hearing it for the first time, it strikes me as having\n4 potential plausibility. That was not present in the papers, so\n5 I certainly will need briefing and to think about that question\n6 more.\n7 MR. EVERDELL: I can assure you if it had been really\n8 teed up, I would have addressed it. But I would note that\n9 there is a time difference between the Mann Act conspiracies\n10 and the sex trafficking counts.\n11 The sex trafficking counts are 2001 to 2004, and this\n12 particular individual was well over the age of consent by the\n13 time 2001 to 2004 is going on. She's alleging events that took\n14 place in '94 and '95 when she's 17 and 18. 2001 to 2004 is\n15 well past the age of consent in any of these relevant\n16 jurisdictions.\n17 I don't see how it is probative of the defendant's\n18 intent -- when someone is presumably allegedly engaging in\n19 perfectly legal sex acts, how that is probative of intent,\n20 knowledge, or any of the above of a sex trafficking conspiracy.\n21 And by the way, there's no allegation that she got paid, so how\n22 are we talking about sex trafficking?\n23 It seems like the government is trying to take an\n24 episode of legal conduct and make it sound salacious for the\n25 jury and use it as direct evidence of conspiracies for which it",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
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      "type": "printed",
      "content": "DOJ-OGR-00007132",
      "position": "footer"
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  "entities": {
    "people": [
      "MR. EVERDELL"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "11/15/21",
      "2001",
      "2004",
      "'94",
      "'95"
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      "1:20-cr-00330-PAE",
      "465",
      "DOJ-OGR-00007132"
    ]
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}