mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014341.json

{
  "document_metadata": {
    "page_number": "37",
    "document_number": "765",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 37 of 95 2775 LCI1MAX1\nthey can convict based on the illegal sexual activity as it relates to Kate and as it relates to Annie. Annie only relates to the conspiracy counts, at least as to these Mann Act charges, and the jury is going to be instructed here that the relevant illegal sexual activity has to be the violation of the New York offense. So again, there's no risk that the jury will think that the sexual contact that happened in New Mexico is something that on its own is sufficient to show the illegal sexual activity required by the statute. So, here, in the full set of instructions, there's no need for an additional instruction, especially on top of the fact that the Court has already given these limiting instructions to the jury.\nTHE COURT: All right. I agree with that.\nMR. EVERDELL: Well, your Honor, there's one other issue, which is the part that's not in the typewritten instruction I handed you, which is the fact that Jane testified about traveling to New Mexico at various times in her testimony. And there was I think one trip she may have said she was under the age of 16, which -- 15 or 16 I think is what she said as to that trip, which we believe is the actual legal age of consent in New Mexico; but she also testified about other travel to New Mexico, where events took place, where sexual contact took place, and so I think with respect to that, we are going to need some kind of instruction to the jury that if she's above the age of consent in New Mexico, that can't be\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014341",
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      "content": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 37 of 95 2775 LCI1MAX1",
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    {
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      "content": "they can convict based on the illegal sexual activity as it relates to Kate and as it relates to Annie. Annie only relates to the conspiracy counts, at least as to these Mann Act charges, and the jury is going to be instructed here that the relevant illegal sexual activity has to be the violation of the New York offense. So again, there's no risk that the jury will think that the sexual contact that happened in New Mexico is something that on its own is sufficient to show the illegal sexual activity required by the statute. So, here, in the full set of instructions, there's no need for an additional instruction, especially on top of the fact that the Court has already given these limiting instructions to the jury.\nTHE COURT: All right. I agree with that.\nMR. EVERDELL: Well, your Honor, there's one other issue, which is the part that's not in the typewritten instruction I handed you, which is the fact that Jane testified about traveling to New Mexico at various times in her testimony. And there was I think one trip she may have said she was under the age of 16, which -- 15 or 16 I think is what she said as to that trip, which we believe is the actual legal age of consent in New Mexico; but she also testified about other travel to New Mexico, where events took place, where sexual contact took place, and so I think with respect to that, we are going to need some kind of instruction to the jury that if she's above the age of consent in New Mexico, that can't be",
      "position": "main content"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00014341",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Kate",
      "Annie",
      "Jane",
      "MR. EVERDELL"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New York",
      "New Mexico"
    ],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "765",
      "DOJ-OGR-00014341"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a discussion about jury instructions and the Mann Act charges. The text is mostly printed, with some dialogue between the court and MR. EVERDELL. There are no visible redactions or damage to the document."
}