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    "page_number": "35",
    "document_number": "739",
    "date": "08/10/22",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 35 of 43 35 LBNAMAXTps\n\nNew Mexico law if that's something the government is going to show.\n\nMR. ROHRBACH: Your Honor, we completely agree that our charging theory is just a violation of the New York statute and not the New Mexico statute, or any particular New Mexico statute. Our point is that it is not a straightforward question that any sexual activity that occurred in New Mexico was necessarily above New Mexico's own age of consent. So at least the legal accuracy of that has not been established at this point.\n\nTHE COURT: Will it be an issue in trial?\n\nMR. ROHRBACH: No, your Honor, because the government is not planning to put on evidence aimed at meeting any particular New Mexico offense, since that's not the charges that we've established in this case. That's just a point in terms of the accuracy of the proposed jury instruction -- that is, whether the sexual conduct was legal or illegal within New Mexico.\n\nTHE COURT: So what I had said was, \"I anticipate you'll hear testimony from the next witness about sexual conduct that she says she had with Mr. Epstein in New Mexico.\" And then I had suggested, because it's what I understood from the parties, \"I instruct you that because the witness was over the age of consent in New Mexico at the relevant time period, the sexual conduct she says occurred with Mr. Epstein was not\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00011656",
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      "content": "New Mexico law if that's something the government is going to show.\n\nMR. ROHRBACH: Your Honor, we completely agree that our charging theory is just a violation of the New York statute and not the New Mexico statute, or any particular New Mexico statute. Our point is that it is not a straightforward question that any sexual activity that occurred in New Mexico was necessarily above New Mexico's own age of consent. So at least the legal accuracy of that has not been established at this point.\n\nTHE COURT: Will it be an issue in trial?\n\nMR. ROHRBACH: No, your Honor, because the government is not planning to put on evidence aimed at meeting any particular New Mexico offense, since that's not the charges that we've established in this case. That's just a point in terms of the accuracy of the proposed jury instruction -- that is, whether the sexual conduct was legal or illegal within New Mexico.\n\nTHE COURT: So what I had said was, \"I anticipate you'll hear testimony from the next witness about sexual conduct that she says she had with Mr. Epstein in New Mexico.\" And then I had suggested, because it's what I understood from the parties, \"I instruct you that because the witness was over the age of consent in New Mexico at the relevant time period, the sexual conduct she says occurred with Mr. Epstein was not",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00011656",
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  "entities": {
    "people": [
      "MR. ROHRBACH",
      "Mr. Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New Mexico",
      "New York"
    ],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "739",
      "DOJ-OGR-00011656"
    ]
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}