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    "page_number": "82",
    "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 82 of 127 82 LB1TMAX3\n\n1 is entirely irrelevant, every single one of them.\n2 So our view, Judge, is that her testimony should not\n3 come in as direct evidence of the conspiracy. At best, what\n4 the government has articulated -- they keep talking about\n5 pattern, intent, knowledge. That's classic 404(b). So if\n6 we're going to talk about this witness's testimony at all, we\n7 should be talking about it in terms of 404(b) and whether it\n8 meets that test. And it doesn't, your Honor. It is not\n9 probative of knowledge or intent.\n10 For a crime that charges causing someone to travel to\n11 engage in a legal sex act as a minor, if that person is neither\n12 a minor, did not travel with the intent of doing something\n13 illegal because it was not illegal in any of those\n14 jurisdictions, whatever happened, according to her own\n15 testimony, it is not probative of any of those crimes and for\n16 404(b) purposes, too.\n17 Pattern, Judge, if it's modus operandi, that need to\n18 be extremely specific before that can come in as modus operandi\n19 evidence. We can't talk about engaging in social pleasantries\n20 and polite conversation with someone as a pattern. That is not\n21 a pattern that passes muster.\n22 Furthermore, there are huge 403 issues with this\n23 witness's testimony. If she talks about how she felt about\n24 these experiences, that is eliciting sympathy from the jury.\n25 It is not legally probative and it will lead them to think that\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007133",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 82 of 127 82 LB1TMAX3",
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      "content": "1 is entirely irrelevant, every single one of them.\n2 So our view, Judge, is that her testimony should not\n3 come in as direct evidence of the conspiracy. At best, what\n4 the government has articulated -- they keep talking about\n5 pattern, intent, knowledge. That's classic 404(b). So if\n6 we're going to talk about this witness's testimony at all, we\n7 should be talking about it in terms of 404(b) and whether it\n8 meets that test. And it doesn't, your Honor. It is not\n9 probative of knowledge or intent.\n10 For a crime that charges causing someone to travel to\n11 engage in a legal sex act as a minor, if that person is neither\n12 a minor, did not travel with the intent of doing something\n13 illegal because it was not illegal in any of those\n14 jurisdictions, whatever happened, according to her own\n15 testimony, it is not probative of any of those crimes and for\n16 404(b) purposes, too.\n17 Pattern, Judge, if it's modus operandi, that need to\n18 be extremely specific before that can come in as modus operandi\n19 evidence. We can't talk about engaging in social pleasantries\n20 and polite conversation with someone as a pattern. That is not\n21 a pattern that passes muster.\n22 Furthermore, there are huge 403 issues with this\n23 witness's testimony. If she talks about how she felt about\n24 these experiences, that is eliciting sympathy from the jury.\n25 It is not legally probative and it will lead them to think that",
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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-00007133",
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    "people": [
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "11/15/21"
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      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007133"
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}