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    "page_number": "76",
    "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 76 of 127\nLB1TMAX3\n1 across when she describes it.\n2 What I mean is not that the relevance turns on whether\n3 or not she consented to that conduct, but the way in which that\n4 occurred closely mirrors exactly how that occurred with other\n5 victims. So in terms of proving the methods of the conspiracy,\n6 the means they employed, the defendant's role in the\n7 conspiracy, all of which is direct proof of the defendant's\n8 guilt, this victim's testimony will be corroborative and\n9 establish the defendant's knowledge.\n10 THE COURT: You're saying that would be true\n11 regardless of the age of this individual. I could keep doing a\n12 hypothetical, 25, 30, it doesn't matter, from your perspective,\n13 it would be relevant to establishing the conspiracy because it\n14 occurred at the same time?\n15 MS. MOE: Your Honor, I could see universe in which\n16 there were an outer limit on the age a hypothetical victim\n17 where this would be relevant. Our view is that the age of this\n18 victim makes it particularly relevant, but it's the other\n19 aspects of the course of conduct which are corroborative and\n20 make this direct evidence. Here, this victim was 17, in close\n21 proximity to the age of the other victims, and so her\n22 testimony, among other things, establishes the defendant's\n23 knowledge and awareness of a certain sexual preference for\n24 girls under the age of 18.\n25 THE COURT: But under the age of 18 is legally\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007127",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 76 of 127",
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    {
      "type": "printed",
      "content": "LB1TMAX3",
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      "type": "printed",
      "content": "1 across when she describes it.\n2 What I mean is not that the relevance turns on whether\n3 or not she consented to that conduct, but the way in which that\n4 occurred closely mirrors exactly how that occurred with other\n5 victims. So in terms of proving the methods of the conspiracy,\n6 the means they employed, the defendant's role in the\n7 conspiracy, all of which is direct proof of the defendant's\n8 guilt, this victim's testimony will be corroborative and\n9 establish the defendant's knowledge.",
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      "content": "10 THE COURT: You're saying that would be true\n11 regardless of the age of this individual. I could keep doing a\n12 hypothetical, 25, 30, it doesn't matter, from your perspective,\n13 it would be relevant to establishing the conspiracy because it\n14 occurred at the same time?",
      "position": "main"
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      "content": "15 MS. MOE: Your Honor, I could see universe in which\n16 there were an outer limit on the age a hypothetical victim\n17 where this would be relevant. Our view is that the age of this\n18 victim makes it particularly relevant, but it's the other\n19 aspects of the course of conduct which are corroborative and\n20 make this direct evidence. Here, this victim was 17, in close\n21 proximity to the age of the other victims, and so her\n22 testimony, among other things, establishes the defendant's\n23 knowledge and awareness of a certain sexual preference for\n24 girls under the age of 18.",
      "position": "main"
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    {
      "type": "printed",
      "content": "25 THE COURT: But under the age of 18 is legally",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00007127",
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    "people": [
      "MS. MOE"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "11/15/21"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "465",
      "DOJ-OGR-00007127"
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}