mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014329.json

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  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 25 of 95 2763 LCI1MAX1\ndifferent statute, it's quite a different statute. It's the production of child pornography statute. And also, the question in Broxmeyer was somewhat different. It was a sufficiency of the evidence question about whether the government's evidence showed that the persuasion or inducement occurred before the production of the child pornography, and so that's -- I don't think that this case stands for a particular, like, form of causal nexus that's required between \"persuasion,\" \"inducement,\" or \"coercion\" and the travel itself. I think the jury will be confused by an instruction along those lines because it suggests that some amount of causation is required above the inherent causation in the statutory terms of inducement or enticement. Those are words of causation, but they are sort of words of causation in the plain and ordinary sense and not in any greater or more significant sense that I think a further instruction on that point would suggest.\nMR. EVERDELL: Your Honor, if I could just respond. I don't think this is heightening the level of proof. I think this is simply -- the opinion is simply explaining what is required by those words, \"persuasion,\" \"inducement,\" \"enticement,\" and those words are the exact same words that are used in the statute, so I don't think the context of the case really matters in terms of what those words mean. There may be some inherent causation built into these words, but this is\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00014329",
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      "content": "different statute, it's quite a different statute. It's the production of child pornography statute. And also, the question in Broxmeyer was somewhat different. It was a sufficiency of the evidence question about whether the government's evidence showed that the persuasion or inducement occurred before the production of the child pornography, and so that's -- I don't think that this case stands for a particular, like, form of causal nexus that's required between \"persuasion,\" \"inducement,\" or \"coercion\" and the travel itself. I think the jury will be confused by an instruction along those lines because it suggests that some amount of causation is required above the inherent causation in the statutory terms of inducement or enticement. Those are words of causation, but they are sort of words of causation in the plain and ordinary sense and not in any greater or more significant sense that I think a further instruction on that point would suggest.",
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      "content": "MR. EVERDELL: Your Honor, if I could just respond. I don't think this is heightening the level of proof. I think this is simply -- the opinion is simply explaining what is required by those words, \"persuasion,\" \"inducement,\" \"enticement,\" and those words are the exact same words that are used in the statute, so I don't think the context of the case really matters in terms of what those words mean. There may be some inherent causation built into these words, but this is",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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