mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014328.json

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    "page_number": "24 of 95",
    "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 24 of 95 2762 LCI1MAX1\nword \"coerced\" we would like to remove. We understand that's been overruled by the Court.\nOkay. But there is some additional language we would propose at the end of line 6, and this is something that I raised I think in a letter submission in -- or not in a letter -- orally at the Rule 29 argument. It's based on U.S. v. Broxmeyer, which, as I argued to the Court at the Rule 29 argument, the words \"persuade,\" \"induce,\" and \"entice\" are words of causation and they need to cause an effect, and so what we would propose after the sentence, \"The terms 'persuaded,' 'induced,' 'enticed,' and 'coerced' have their ordinary, everyday meanings,\" we would propose adding the following language: \"This element is satisfied only if the 'persuasion,' 'inducement,' or 'enticement' caused Jane to travel in interstate commerce as alleged in the indictment.\"\nWe're basing that on U.S. v. Broxmeyer, interpreting those words from a different but related statute.\nTHE COURT: Give me one moment.\nMR. EVERDELL: I have a copy of Broxmeyer, your Honor, if you'd like to see it.\nTHE COURT: Sure. I'll take it.\nMR. EVERDELL: Your Honor, I believe it's on page 125 of the opinion.\nTHE COURT: Okay. The relevant language.\nMR. ROHRBACH: Your Honor, this is not just a\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014328",
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      "content": "word \"coerced\" we would like to remove. We understand that's been overruled by the Court.\nOkay. But there is some additional language we would propose at the end of line 6, and this is something that I raised I think in a letter submission in -- or not in a letter -- orally at the Rule 29 argument. It's based on U.S. v. Broxmeyer, which, as I argued to the Court at the Rule 29 argument, the words \"persuade,\" \"induce,\" and \"entice\" are words of causation and they need to cause an effect, and so what we would propose after the sentence, \"The terms 'persuaded,' 'induced,' 'enticed,' and 'coerced' have their ordinary, everyday meanings,\" we would propose adding the following language: \"This element is satisfied only if the 'persuasion,' 'inducement,' or 'enticement' caused Jane to travel in interstate commerce as alleged in the indictment.\"\nWe're basing that on U.S. v. Broxmeyer, interpreting those words from a different but related statute.",
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      "type": "printed",
      "content": "THE COURT: Give me one moment.\nMR. EVERDELL: I have a copy of Broxmeyer, your Honor, if you'd like to see it.\nTHE COURT: Sure. I'll take it.\nMR. EVERDELL: Your Honor, I believe it's on page 125 of the opinion.\nTHE COURT: Okay. The relevant language.\nMR. ROHRBACH: Your Honor, this is not just a",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014328",
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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",
      "DOJ-OGR-00014328"
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}