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    "page_number": "19",
    "document_number": "765",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 19 of 95 2757 LCI1MAX1 1 MR. EVERDELL: Or in brackets because it's an addition to the statutory text. 2 3 MR. ROHRBACH: Your Honor, the government does not agree with this one. The jury could conclude that the minors had been coerced for the enticement counts. There's expert testimony from Dr. Rocchio about how these relationships sort of evolved; there's testimony from Jane in the record about how, toward the end of her relationship with Mr. Epstein, she felt like she was compelled to continue answering the phone and would drop everything because she had no other choice. I think the jury could conclude that these victims were coerced. \"Coercion\" in this context just bears its ordinary and natural meaning, and there's no reason to delete it from the charge. 13 14 MR. EVERDELL: Well, your Honor, I agree I know we give normal meanings to these words, and coercion in my normal meaning implies some sort of force, or at least of violence or something, and there's no evidence of that in the record. 17 18 MR. ROHRBACH: It's an argument that the defense is free to make to the jury. 19 20 THE COURT: Well, what's the legal basis for the notion that coercion as used here textually requires force? 21 22 MR. EVERDELL: Your Honor, as in Sand, they just say \"given the normal everyday meaning.\" It's not particularly helpful, but I guess that can differ by person. My normal everyday meaning of \"coercion\" means some sort of force being 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014323",
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      "content": "1 MR. EVERDELL: Or in brackets because it's an addition to the statutory text. 2 3 MR. ROHRBACH: Your Honor, the government does not agree with this one. The jury could conclude that the minors had been coerced for the enticement counts. There's expert testimony from Dr. Rocchio about how these relationships sort of evolved; there's testimony from Jane in the record about how, toward the end of her relationship with Mr. Epstein, she felt like she was compelled to continue answering the phone and would drop everything because she had no other choice. I think the jury could conclude that these victims were coerced. \"Coercion\" in this context just bears its ordinary and natural meaning, and there's no reason to delete it from the charge. 13 14 MR. EVERDELL: Well, your Honor, I agree I know we give normal meanings to these words, and coercion in my normal meaning implies some sort of force, or at least of violence or something, and there's no evidence of that in the record. 17 18 MR. ROHRBACH: It's an argument that the defense is free to make to the jury. 19 20 THE COURT: Well, what's the legal basis for the notion that coercion as used here textually requires force? 21 22 MR. EVERDELL: Your Honor, as in Sand, they just say \"given the normal everyday meaning.\" It's not particularly helpful, but I guess that can differ by person. My normal everyday meaning of \"coercion\" means some sort of force being",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00014323",
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  "entities": {
    "people": [
      "MR. EVERDELL",
      "MR. ROHRBACH",
      "Dr. Rocchio",
      "Jane",
      "Mr. Epstein"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "765",
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