{ "document_metadata": { "page_number": "26", "document_number": "765", "date": "08/10/22", "document_type": "court transcript", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 26 of 95 2764 LCI1MAX1\nexplaining the fact that that causation needs to exist. In case there's any doubt in the minds of the jurors, there does need to be causation. There has to be an effect from the inducement, the persuasion, the enticement.\nMR. ROHRBACH: First there has to be some sort of causal relationship. That's what the word \"inducement\" means, for example, as a form of a causal relationship. I'm certainly not aware of any case or treatise that provided this instruction. Maybe perhaps defense counsel is. But, you know, the fact that it is in Broxmeyer does not mean it's appropriate to give a further and more specific instruction about causation than is already inherent in the ordinary meaning of these words.\nTHE COURT: Just so I have my head around it, the specific suggestion was what, Mr. Everdell?\nMR. EVERDELL: \"This element is satisfied only if the persuasion, inducement, or enticement caused Jane,\" or we can say \"caused the individual,\" \"to travel in interstate commerce as alleged in the indictment.\"\nMR. ROHRBACH: The problem, your Honor, is that to the extent that those words already mean to cause, inducement has a causal meaning, persuasion has a causal meaning. It's already in the instruction. And to say, you can only satisfy those words if she caused the travel suggests that there are two requirements -- there's the requirement that the defendant\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016952", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 26 of 95 2764 LCI1MAX1", "position": "header" }, { "type": "printed", "content": "explaining the fact that that causation needs to exist. In case there's any doubt in the minds of the jurors, there does need to be causation. There has to be an effect from the inducement, the persuasion, the enticement.\nMR. ROHRBACH: First there has to be some sort of causal relationship. That's what the word \"inducement\" means, for example, as a form of a causal relationship. I'm certainly not aware of any case or treatise that provided this instruction. Maybe perhaps defense counsel is. But, you know, the fact that it is in Broxmeyer does not mean it's appropriate to give a further and more specific instruction about causation than is already inherent in the ordinary meaning of these words.\nTHE COURT: Just so I have my head around it, the specific suggestion was what, Mr. Everdell?\nMR. EVERDELL: \"This element is satisfied only if the persuasion, inducement, or enticement caused Jane,\" or we can say \"caused the individual,\" \"to travel in interstate commerce as alleged in the indictment.\"\nMR. ROHRBACH: The problem, your Honor, is that to the extent that those words already mean to cause, inducement has a causal meaning, persuasion has a causal meaning. It's already in the instruction. And to say, you can only satisfy those words if she caused the travel suggests that there are two requirements -- there's the requirement that the defendant", "position": "main" }, { "type": "printed", "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00016952", "position": "footer" } ], "entities": { "people": [ "MR. ROHRBACH", "MR. EVERDELL", "Jane" ], "organizations": [ "SOUTHERN DISTRICT REPORTERS, P.C." ], "locations": [], "dates": [ "08/10/22" ], "reference_numbers": [ "1:20-cr-00330-AJN", "765", "DOJ-OGR-00016952" ] }, "additional_notes": "The document appears to be a court transcript with a discussion about the legal concept of causation and inducement. The text is mostly printed, with no visible handwriting or stamps. The footer contains the name and contact information of the court reporter and a reference number." }