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    "page_number": "72",
    "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 72 of 127 72 LB1TMAX3\nVictims' Rights Act, so we want to confer with victims' counsel on that issue as well before we reach a conclusion on that.\nThe definition set forth in the restitution statute, which is 18 USC 3663(a)(2), for purposes of the section, the term \"victim\" means a person directly and proximately harmed as a result of the commission of an offense for which restitution may be ordered.\nSo that's the particular issue that we just want to think through before we reach a conclusion on in particular because we're mindful of the Crime Victims' Rights Act. So I apologize, it's not my intention, certainly, to fight the hypothetical, we wanted to be thoughtful about that issue.\nTHE COURT: You will get me your views on that question with respect to restitution, but as I understand your initial point, for purposes, as you said, of the elements of establishing any of the offenses, the government's view is that this individual is not a victim in the sense -- granting that restitution's definition of \"victim\" could be broader than those for whom the government's proof of elements as to the charged account would show to be victims, I think that's the distinction you're trying to draw.\nMS. MOE: Your Honor, our position is that we recognize Minor Victim-3's testimony alone would not satisfy the elements of the conspiracy count in which the overt acts appear, our view is nonetheless that it's direct evidence.\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007123",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 72 of 127 72 LB1TMAX3",
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      "content": "Victims' Rights Act, so we want to confer with victims' counsel on that issue as well before we reach a conclusion on that.\nThe definition set forth in the restitution statute, which is 18 USC 3663(a)(2), for purposes of the section, the term \"victim\" means a person directly and proximately harmed as a result of the commission of an offense for which restitution may be ordered.\nSo that's the particular issue that we just want to think through before we reach a conclusion on in particular because we're mindful of the Crime Victims' Rights Act. So I apologize, it's not my intention, certainly, to fight the hypothetical, we wanted to be thoughtful about that issue.",
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      "content": "THE COURT: You will get me your views on that question with respect to restitution, but as I understand your initial point, for purposes, as you said, of the elements of establishing any of the offenses, the government's view is that this individual is not a victim in the sense -- granting that restitution's definition of \"victim\" could be broader than those for whom the government's proof of elements as to the charged account would show to be victims, I think that's the distinction you're trying to draw.",
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    {
      "type": "printed",
      "content": "MS. MOE: Your Honor, our position is that we recognize Minor Victim-3's testimony alone would not satisfy the elements of the conspiracy count in which the overt acts appear, our view is nonetheless that it's direct evidence.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00007123",
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  "entities": {
    "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",
      "Document 465",
      "18 USC 3663(a)(2)",
      "DOJ-OGR-00007123"
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}