{
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    "page_number": "87",
    "document_number": "465",
    "date": "11/15/21",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 87 of 127 87 LB1TMAX3 intertwined with the evidence, again with respect to the Mann Act, and it's not necessary to complete the story of the crime on trial, so I don't think it can be direct evidence of the Mann Act counts. There's a prejudice analysis that I will get to in a moment, but as proffered, it strikes me the testimony may serve a proper purpose under 404(b) as relevant testimony of the defendant's knowledge, intent and alleged MO. For example, the proffered testimony could tend to establish that the defendant was aware of, for example, the sexualized nature of the alleged massages. So if the argument is massages are not sexual or there's no knowledge, this witness might have evidence and testimony that could refute that point. The testimony could support that the defendant asked the witness to recruit underage girls to engage in similar sexualized massages which tends to make the alleged MO more probable. The testimony that this witness was allegedly groomed by the defendant does not tend to establish the defendant's knowledge, intent or MO to groom minor victims alone without more, the kind of testimony I indicated, because this witness was not a minor pursuant to the age of consent laws in any of the relevant jurisdictions. I will say I think there may be room for 404(b) testimony, but there's a risk of a prejudice, the risk of confusing issues and misleading the jury. A limiting SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007138",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 87 of 127 87 LB1TMAX3",
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    {
      "type": "printed",
      "content": "intertwined with the evidence, again with respect to the Mann Act, and it's not necessary to complete the story of the crime on trial, so I don't think it can be direct evidence of the Mann Act counts. There's a prejudice analysis that I will get to in a moment, but as proffered, it strikes me the testimony may serve a proper purpose under 404(b) as relevant testimony of the defendant's knowledge, intent and alleged MO. For example, the proffered testimony could tend to establish that the defendant was aware of, for example, the sexualized nature of the alleged massages. So if the argument is massages are not sexual or there's no knowledge, this witness might have evidence and testimony that could refute that point. The testimony could support that the defendant asked the witness to recruit underage girls to engage in similar sexualized massages which tends to make the alleged MO more probable. The testimony that this witness was allegedly groomed by the defendant does not tend to establish the defendant's knowledge, intent or MO to groom minor victims alone without more, the kind of testimony I indicated, because this witness was not a minor pursuant to the age of consent laws in any of the relevant jurisdictions. I will say I think there may be room for 404(b) testimony, but there's a risk of a prejudice, the risk of confusing issues and misleading the jury. A limiting",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00007138",
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  "entities": {
    "people": [],
    "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-00007138"
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  "additional_notes": "The document appears to be a court transcript or legal document, discussing the admissibility of certain testimony under Rule 404(b) of the Federal Rules of Evidence. The text is typed, and there are no visible handwritten notes or stamps."
}