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    "page_number": "70",
    "document_number": "465",
    "date": "11/15/21",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 70 of 127\nLB1TMAX3\n1 based on that conduct alone and the evidence based on that conduct alone, we submit that, given the course of conduct in the charged conspiracy, that Minor Victim-3 is a victim of an ongoing conspiracy, which is one of agreement and intent.\n2\n3 We submit that her testimony alone wouldn't establish a violation of the Mann Act, and without the other circumstances of other victim testimony, we couldn't establish that there was an ongoing intent to transport minor victims.\n4 But given that the crime here is conspiracy and one of agreements and mental states and not about attempts to violate certain statues or agreements to do so, it's about the intention at the time of agreement during the course of a span of conduct.\n5\n6 THE COURT: But it has to be an intention to engage in an illegal act.\n7\n8 MS. MOE: That's correct, your Honor.\n9\n10 THE COURT: And so I think I need an answer to the question. There is a distinction, surely, between criminality and evidence of criminality. You have evidence of criminality, which is not itself criminality, for sure. You have 403 questions and the like. But I need to know the government's position I think for a number of things in issue, including Defendant's 4. So you have confirmed that the defendant couldn't be found guilty of any crimes charged based on the conduct alleged with respect to what you refer to as alleged\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007121",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 70 of 127",
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      "content": "LB1TMAX3",
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      "type": "printed",
      "content": "1 based on that conduct alone and the evidence based on that conduct alone, we submit that, given the course of conduct in the charged conspiracy, that Minor Victim-3 is a victim of an ongoing conspiracy, which is one of agreement and intent.\n2\n3 We submit that her testimony alone wouldn't establish a violation of the Mann Act, and without the other circumstances of other victim testimony, we couldn't establish that there was an ongoing intent to transport minor victims.\n4 But given that the crime here is conspiracy and one of agreements and mental states and not about attempts to violate certain statues or agreements to do so, it's about the intention at the time of agreement during the course of a span of conduct.\n5\n6 THE COURT: But it has to be an intention to engage in an illegal act.\n7\n8 MS. MOE: That's correct, your Honor.\n9\n10 THE COURT: And so I think I need an answer to the question. There is a distinction, surely, between criminality and evidence of criminality. You have evidence of criminality, which is not itself criminality, for sure. You have 403 questions and the like. But I need to know the government's position I think for a number of things in issue, including Defendant's 4. So you have confirmed that the defendant couldn't be found guilty of any crimes charged based on the conduct alleged with respect to what you refer to as alleged",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "type": "printed",
      "content": "DOJ-OGR-00007121",
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  "entities": {
    "people": [
      "Minor Victim-3",
      "MS. MOE"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "11/15/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007121"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}