mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016950.json

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    "page_number": "24",
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    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 24 of 95\nLCI1MAX1\n1 word \"coerced\" we would like to remove. We understand that's\n2 been overruled by the Court.\n3 Okay. But there is some additional language we would\n4 propose at the end of line 6, and this is something that I\n5 raised I think in a letter submission in -- or not in a\n6 letter -- orally at the Rule 29 argument. It's based on U.S.\n7 v. Broxmeyer, which, as I argued to the Court at the Rule 29\n8 argument, the words \"persuade,\" \"induce,\" and \"entice\" are\n9 words of causation and they need to cause an effect, and so\n10 what we would propose after the sentence, \"The terms\n11 'persuaded,' 'induced,' 'enticed,' and 'coerced' have their\n12 ordinary, everyday meanings,\" we would propose adding the\n13 following language: \"This element is satisfied only if the\n14 'persuasion,' 'inducement,' or 'enticement' caused Jane to\n15 travel in interstate commerce as alleged in the indictment.\"\n16 We're basing that on U.S. v. Broxmeyer, interpreting those\n17 words from a different but related statute.\n18 THE COURT: Give me one moment.\n19 MR. EVERDELL: I have a copy of Broxmeyer, your Honor,\n20 if you'd like to see it.\n21 THE COURT: Sure. I'll take it.\n22 MR. EVERDELL: Your Honor, I believe it's on page 125\n23 of the opinion.\n24 THE COURT: Okay. The relevant language.\n25 MR. ROHRBACH: Your Honor, this is not just a\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00016950",
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      "content": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 24 of 95",
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      "content": "LCI1MAX1",
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      "content": "1 word \"coerced\" we would like to remove. We understand that's\n2 been overruled by the Court.\n3 Okay. But there is some additional language we would\n4 propose at the end of line 6, and this is something that I\n5 raised I think in a letter submission in -- or not in a\n6 letter -- orally at the Rule 29 argument. It's based on U.S.\n7 v. Broxmeyer, which, as I argued to the Court at the Rule 29\n8 argument, the words \"persuade,\" \"induce,\" and \"entice\" are\n9 words of causation and they need to cause an effect, and so\n10 what we would propose after the sentence, \"The terms\n11 'persuaded,' 'induced,' 'enticed,' and 'coerced' have their\n12 ordinary, everyday meanings,\" we would propose adding the\n13 following language: \"This element is satisfied only if the\n14 'persuasion,' 'inducement,' or 'enticement' caused Jane to\n15 travel in interstate commerce as alleged in the indictment.\"\n16 We're basing that on U.S. v. Broxmeyer, interpreting those\n17 words from a different but related statute.",
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      "content": "18 THE COURT: Give me one moment.\n19 MR. EVERDELL: I have a copy of Broxmeyer, your Honor,\n20 if you'd like to see it.\n21 THE COURT: Sure. I'll take it.\n22 MR. EVERDELL: Your Honor, I believe it's on page 125\n23 of the opinion.\n24 THE COURT: Okay. The relevant language.\n25 MR. ROHRBACH: Your Honor, this is not just a",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00016950",
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-AJN",
      "765",
      "29",
      "125",
      "DOJ-OGR-00016950",
      "(212) 805-0300"
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